Short & Sweet no. 7
Which offshore aircraft registrations can be used with Temporary Admissions when flying within the EU and UK?

Added September 2021

  • Chose the right registration to fly freely
  • You might not want to use the Isle of Man (M) registration
  • What is the pitfall?
Introduction
Any aircraft flying into the EU or the UK will fly under customs control using either the Temporary Admission (TA) procedure or full importation. There are no other options. The TA procedure can only be used by outsiders where the aircraft is owned (including any UBOs), operated, registered, and based outside the EU and the UK, leaving insiders with only one option, namely full importation.

We are often asked which offshore aircraft registrations can be used with TA when an aircraft is being used both within the EU and the UK by an owner (including the UBO) and/or by an operator which resides outside the EU or the UK.

Most aircraft registrations can be used without problems
Most of the popular offshore aircraft registrations can be used all-round within the EU and the UK, with a few exceptions. Please, have a look at the table below, and please notice that an EU aircraft registration can never be used with TA when flying within the EU.

Jurisdiction
Area flying
Area flying
Aruba (P4)
Bahamas (VP-B)
Bermuda (VP-B or VQ-B)
The British Virgin Islands (VP-L)
Cayman Islands (VP-C)
Cyprus (5B) *
Guernsey (2) **
Ireland (EI) *
Isle of Man (M) ***
Jersey (ZJ) **
Malta (9H) *
San Marino (T7) ****
Switzerland (HB)
USA (N)

* Cyprus, Ireland, Malta are all inside the customs territory of the Union (EU)
** The Channel Islands are all outside the customs territory of the UK
*** The Isle of Man is inside the customs territory of the UK
**** San Marino is outside the customs territory of the Union (EU)

You might not want to use the Isle of Man (M) registration
It is perfectly fine to use the M-registration or an Isle of Man owner entity (including the UBO) with regards to the EU regulation and when flying within the EU, if the total setup meets the requirements for the Temporary Admission procedure. However, the same setup may create vast problems if flying to the UK. As we anticipate most aircraft will eventually fly to the UK or that every owner wants to at least have the possibility, we suggest not using an Isle of Man owner entity or the M-registration.

An Isle of Man connection means that the aircraft cannot use the TA procedure when flying to the UK, leaving a full UK importation as the only option available. The HMRC (British customs) have in many ways limited the access to aircraft importations unless the imposed VAT (20% of the aircraft’s value) is fully paid without the possibility to reclaim. The risk is that the aircraft will be impounded by the HMRC.

How can we help?
If you have questions about the above, please do not hesitate to contact us. We offer a cost-free introduction and analysis of the owner, user, and operator scenario to find the best option for you when flying within the EU. Please, feel free to contact us at any time.

Selected links covering this issue
Theme page Temporary Admission
Short & Sweet – mail no. 3: Is a full importation needed in both the UK and the EU27?


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