COMMERCIAL AND CORPORATE FLYING WITHIN THE EUROPEAN UNION

Short & Sweet no. 19
The real differences between full importation and Temporary Admission

Added 2023 – Updated June 2025

Select the flight privileges needed
See the risks and liabilities involved
Get a basis for a decision on how to fly within the EU
Choose the most applicable customs procedure

We have created a simple overview of the main decision points when choosing between full importation and Temporary Admission. The overview is made primarily for EU outsiders but can also provide EU insiders with insight into the same issues.

The customs aspect of flying within the EU

Any aircraft flying into the EU will fly under customs control using either Temporary Admisison (TA) or full importation. There are no other options. If the aircraft is not already fully imported, the aircraft will automatically be considered as flying under TA even though the owner or operator has not themselves taken any action to activate this procedure or realized that their aircraft is flying under TA. The TA procedure is thus always required for non-EU imported aircraft, even for flights with only one stop within the EU. Here, non-compliance with TA will most likely activate a direct payment of the VAT (ranging from 17-27%) and customs duty (ranging from 2.7-7.7%) for the owner or operator. The TA procedure can only be used by EU outsiders where the aircraft is owned (including any UBOs), operated, registered, and based outside the EU, leaving EU insiders only one option: full importation. EU outsiders can, of course, choose to use full importation instead of TA if they find it beneficial. However, both options can be used commercially, corporately, or privately if applied correctly.

Please have a look at the tables below. Start by identifying the flight privileges needed, then learn about the risks and liabilities involved, and finally decide how to fly within the EU using the most suitable customs procedure.

Nature of the Customs Entry Method	Full importation	Temporary Admission
How are taxes handled?	Payment of all taxes 1)	Suspension of all taxes
Scope of use	Mandatory for EU insiders, but full importation can be chosen as the preferred option by EU outsiders seeking free circulation status	Only possible for EU outsiders

Aircraft Structure and Registration	Full importation	Temporary Admission
Involvement of EU elements	Yes	No 3)

Flight Pattern, Period of Stay, and Base	Full importation	Temporary Admission
Flying to one EU destination	Yes	Yes
Flying internally within the EU	Yes	Yes
Maximum period of stay	Unlimited	Six months per stay 4)
Fixed established EU base	Yes	No 4)

Allowed Persons Onboard	Full importation	Temporary Admission
EU passengers on internal EU-flights	Yes	Yes 5)
EU crew on internal EU-flights	Yes	Yes 6)

Type of Flights Allowed Within the EU	Full importation	Temporary Admission
Corporate flights	Yes	Yes
Private flights	Yes	Yes
Commercial flights, like Part 135 group charters	Yes	Yes
Commercial fligths within EU member states without getting traffic rights (charter permits)	No	No

Green = Possible Yellow = Impossible

If you want deeper insight into the differences between full importation and Temporary Admission, please look at our Quick Guides and choose your preferred operator scenario.

International Charter Operators Private and Corporate Operators

If you want deeper insight into the differences between full importation and Temporary Admission, please look at our Quick Guides and choose your preferred operator scenario.

International Charter Operators

Private and Corporate Operators

Risks and Liabilities	Full importation	Temporary Admission
The biggest risks	Wrong and unaccepted use 2) of the aircraft, e.g., non-business use of a corporate aircraft or non-commercial use of a commercial aircraft	Ramp checks without the operator being ready and able to prove the TA compliance convincingly
Geographical areas that the aircraft must be used correctly according to EU regulation	Worldwide. After the importation, any future use of the aircraft – no matter where – must conform to EU regulations	Only when flying within the EU
Statute of limitation	The VAT liability persists five years after the physical importation	Only when flying within the EU
Is non-business use allowed inside and outside the EU for corporate aircraft (Part 91)?	No, unless all non-business flights worldwide are compensated correctly according to EU regulation	Yes, all kinds of use are allowed. No compensation is required
Is non-commercial use allowed inside and outside the EU if the aircraft was imported using the EU 0% airline exemption (Part 135)?	Generally, no. However, it depends on the exact preconditions in the EU member state where the aircraft was imported. The required minimum commercial use differs between EU member states	Yes, all kinds of use are allowed. No compensation is required

Green = High flexibility Red = Low flexibility and extra liabilities

Legal background for Temporary Admission

The Istanbul Convention from 1990, regulating the worldwide usage of TA, is not very precise, and the EU Commission has been and is continuously publishing various working papers and guidelines to clarify the correct understanding of TA and its usage in the EU. The 2014 working paper from the Union Customs Code Committee (available in English, French, and German) is especially important. Operators should always be aware that these documents are not legally binding for EU member states. Interpretations may vary between member states, which is why it is crucial to have a competent customs agency provide guidance based on the specific setup.

Click here to see a list of known grey zone areas where different interpretations of the TA procedure exist. While none of these areas pose a problem when TA is correctly applied and documented, we find that operators often require guidance to ensure safe and compliant use in these situations.

How can we help?
If you have questions about the above, please do not hesitate to contact us.

Taxes (the VAT) are typically deducted or exempted on the basis that correct use of the aircraft will occur.
San Marino (T7), Guernsey (2), and UK (G) registrations are compatible with TA.
The aircraft can stay up to six months per stay, with multiple entries allowed.
This is based on solid EU working papers, but they are non-binding for EU member states. Thus, it remains a grey zone. All operators should have proper documentation ready during a customs ramp check to secure flights with EU passengers.
No restrictions apply if EU-resident crew are employed by the declarant.
Some business activities are not subject to VAT, such as selected real estate activities, banking and finance, insurance, gaming, and holding companies. The listing is not exhaustive. These activities are not considered correct economic activities in this context.