That EASA concession is UK law too, however, under the Withdrawal Act. The CAA can’t change that, and if they try to, @bathman, write to Richard Moriarty.
The funny thing is how old that concession is. Something like 2014 – here. It received the absolute minimum publicity. It was mentioned on EuroGA but probably nowhere else. Everybody else has their fingers in the pie, one way or another – including the CAA, via its licensing of maintenance companies.
From here, to summarise the current situation, brexit has brought a few improvements for UK pilots
The first two above mean that a ramp chck in the EU has nothing much to look for – apart from contraband 
And it brought some not so good things
Peter wrote:
And it brought some not so good things the CAA can be as useless as they want and you are stuck with it cost sharing rules are partly back to previous i.e. the pilot has to pay his full share, and not just £0.0000001 there is now an outbound GAR as well
- No LPV
- No BIR
Well, yes, UK issued EASA papers (PPL, CPL, the useless LAPL) are all worthless as far as EASA goes.
The BIR was likely to be near-useless anyway, because it doesn’t address the main factors.
no need for any EASA papers when flying an N-reg outside the UK (but you need UK papers, from Dec 2021)
Obviously UK residents don’t need EASA papers anymore…
People resident in UK flying N-reg require
- UK papers
- FAA papers
People resident in EASA countries flying N-reg require
- EASA papers
- FAA papers
no need to prove EU-VAT-paid status of the aircraft (unless you are staying in the EU so long that you create a permanent import)
Again, obviously non EU residents do not need to prove EU-VAT paid status. UK residents need to prove UK-VAT status. When UK was EU, the benefit was that UK VAT paid meant EU VAT paid, and the aircraft could be easily based/sold anywhere in EU, not anymore.
the IMCR is safeguarded (but to be honest EASA gave up on trying to kill it, after lots of abortive attempts c. 2008)
EASA accepted it for UK and additionally introduced E-IR which was now „refurbished“ or even extended to BIR, with the advantage of being valid in all EASA countries.
How exactly is any of this an improvement for UK pilots? I don’t see a single advantage for pilots of UK and EASA brought by BREXIT, to the contrary, it’s making life harder for both (but it was UK people who decided for it).
brexit has brought a few improvements for UK
Really? honestly, BR (FCL, SERA, NCO…) are still applied “as they are” under uk withdrawal bill
Other than PMD & Delta VMC minima (missing BIR intro), I have not seen that many changes?
For VAT, I really don’t see the extra benefit: one need VAT free in UK for their X-reg same as before, sure UKBF or HRMC does not keep nagging about it on ramp checks after every landing but when selling an aircraft, the UK buyer would love to see C88/VAT proof or discount VAT in price (as before), a EU buyer, pay it on import and will share the burden in price (this is new)
Yes I agree, one less item to worry about it in a (systematic/regular) EU ramp check in some places but it is still (theoretically) required for UK (inexistant) ramp checks
Looking back, it turns out I am overall happy that Brexit has happened (let’s say, mix of sad emotions but lot of money out of it), I still think objectively it’s a “net loss for UK pilots”, unless CAA & DfT make serious positive changes out of it, so far not that much…
Not turning this into yet another “opportunity thread” so doing specific points only.
Again, obviously non EU residents do not need to prove EU-VAT paid status. UK residents need to prove UK-VAT status. When UK was EU, the benefit was that UK VAT paid meant EU VAT paid
Exactly, but the unspoken angle is that a VAT ramp inspection in the UK is
) and rarely do “fishing expeditions” in areas they don’t understand (which is any nontrivial area of law)and same actually goes for any ramp check in the UK.
A ramp check on a G (or N) outside the UK is unlikely to yield anything of value, because EU VAT no longer applies. The fuel in the tanks is protected from import duty (ICAO) and you aren’t going to be carrying €10k in your pockets, are you?
and the aircraft could be easily based/sold anywhere in EU, not anymore
If you want to permanently import a plane from the UK (any reg) you have to pay import VAT, so this is same as from the US, which people have been doing since for ever.
The VAT issue has always been the hardest, since ~2005 when it became impossible to obtain a Certificate of Free Circulation.
unless CAA & DfT make serious positive changes out of it, so far not that much
Indeed, but since the DfT is prob99 working towards some treaty with EASA, they simply cannot rub Brussels’ nose in it, by implementing “good stuff”. Maybe later. This is straightforward everyday politics.
It’s just the difference in ramp check? in UK an aircraft has VAT when the pilot ticks “VAT free circulation” in his GAR, then nothing else is required, it’s only when you want to sell that you need to show something
Well, no, the GAR box means nothing. It is just if you don’t tick it, you draw lots of attention
You are right about selling (to a half smart buyer; most aren’t) but abroad you could have got hit for VAT (say 20% of value) just on a ramp check; no selling required.
And, in practice, your plane will be lost for ever until you hand over the money. And if you later do find some VAT import document, you have near zero chance of recovering that money (5 digits) because how are you going to argue with the tax people on the mainland? Wrong language, a few k a day lawyer, good luck with that. Whereas here, you are on your “home turf” for VAT matters, and in a functioning justice system.
And, should you get hit for VAT abroad, are they going to then issue a CofFC? Answer on a postcard No; they will keep the money, and next time they can hit you for another ~20%.
I do have the CofFC so have no dog in this debate (got it in 2005 via a very complicated route when closed for ever soon after) but many/most owners don’t have it and prefer to not kick a sleeping dog. And to me this stuff does matter.
but abroad you could have got hit for VAT (say 20% of value) just on a ramp check; no selling required.
It’s more serious now than before?
Pre-Jan21, I could fly UK to Germany and land anywhere (if I have to or wished) without having to worry about paying Garman VAT import on a UK aircraft (as long as I show HMRC CoFC print bellow, the zoll guys will have to find another excuse to milk it), past-Jan21, one has to be careful not to end up like that Swiss pilot with 25% down as there is no guarantee the aircraft gets accepted into “temporary import”…the situation is slightly different in France, Blegium, I did not dig every bit of customs law out there. Of course, one could argue every airport in EU has customs since new regulation is in force but it’s wishful thinking if the aircraft is not in ‘EU free circulation’
I am more inclined to think the ‘old VAT’ situation was better overall
