airways wrote:
Something else; suppose the acft needs an engine + prop overhaul. Best to do this before or after the reg-change ? Again, intra-EASA.
German and French registers will generally not accept aircraft where the engine and / or prop have exceeded the manufacturers recommended TBO, whether due to time or hours in use. However if the aircraft was on the register before reaching TBO, extensions to the TBO are usually not an issue.
Edited to add: As far as I’m aware, transferring to the German register is just a paperwork exercise, no actual inspection is involved. If you wish to have more details, I can forward you the contact details of a pilot who is currently doing exactly the same, transferring from G to D register.
Thank you, @steve6443 . That information is much appreciated. The situation,however, is that both engine and prop are beyond manufacturer’s TBO. So I understand it correctly that this isn’t a paper exercise anymore (G → D) ?
If the prop on a G-reg is past 6 years, the aircraft is probably already unairworthy, so that needs to be done before further flight. If the engine gets done as well (if it is past TBO and the accepting registry requires this) then afterwards the transfer should again be a paper exercise, relatively speaking.
But as I said you cannot be sure the accepting registry will not uncover some can of worms. They are entitled to take a close look. What you don’t normally (but can do) get is a US-style DAR inspection like you get when going onto N-reg, where he takes the paperwork and the plane “to bits” and finds all kinds of stuff, as well as costing you a few k.
airways wrote:
Thank you, @steve6443 . That information is much appreciated. The situation,however, is that both engine and prop are beyond manufacturer’s TBO. So I understand it correctly that this isn’t a paper exercise anymore (G → D) ?
correct. To transfer you need the prop and engine to be within TBO limits.
I’m in the process of moving my g-reg to a d-reg.
The reason is quite simple. The company owning the plane will leave UK because of BREXIT.
If a G-reg plane is owned by a limited company and the company changes its Registered Office from the UK to say Germany, does this invalidate the aircraft registration?
I don’t think so. In the same way as if the owner of a G-reg revoked his UK passport and took on a German one.
As UK will be a third country, you never know what lies ahead.
There is no guarantee that a foreign company can own an aircraft. I wonder why easyjet have transfered many planes to OE-Reg.
A limited company can not change it registered address to another country. This is a change of legal framework. So basically there will be a new company (GmbH or in my case a SA) these 2 companies merge according EU law and the new company will take over all liabilities and rights. The old ltd. will cease to exist.
So if there is no ltd company from the registration, how can the registration be valid?
mdoerr wrote:
A limited company can not change it registered address to another country. This is a change of legal framework.
This is often possible; it depends on the laws of both countries. I’m not 100% sure about the UK. A change of address to another country entails a change of legal framework, but if both countries’ law accept it, then it happens with continuation of the legal person.
So basically there will be a new company (GmbH or in my case a SA) these 2 companies merge according EU law and the new company will take over all liabilities and rights. The old ltd. will cease to exist.
That’s another way to do it, and the new company can be a subsidiary of the old one, or the other way round (the shareholders create the new company by putting as capital the shares of the old one). Using a EU-law-mandated procedure does indeed create a kind of safe harbour where you don’t need to get a possibly costly legal opinion in each country. By EU-law-mandated, I mean EU law mandates that member states recognise that procedure, not that EU law mandates that subjects of the law actually follow that procedure.
So if there is no ltd company from the registration, how can the registration be valid?
That shouldn’t be a problem right now (law can change in future, obviously). The new company takes over all assets (“rights”) of the old one; the change of owner has to be transcribed at the aircraft register, just like it would have to be transcribed at the relevant registry if the old compan had real estate property.
As UK will be a third country, you never know what lies ahead. There is no guarantee that a foreign company can own an aircraft.
It is up to the UK to decide the ownership rules for a G-reg, and there is no reason for these to change. They have not changed in many decades AFAIK.
I wonder why easyjet have transfered many planes to OE-Reg.
Because they need an EU AOC, etc, to fly their routes.
A limited company can not change it registered address to another country. This is a change of legal framework. So basically there will be a new company (GmbH or in my case a SA) these 2 companies merge according EU law and the new company will take over all liabilities and rights. The old ltd. will cease to exist.
Sure; this is normal. Many years ago I was involved in setting up a French company – a subsidiary of my UK one. It took many months. But that’s nothing to do with aviation.
So if there is no ltd company from the registration, how can the registration be valid?
The reg remains. The owner of the aircraft changes from ABC Ltd to ABC GmbH. The plane is sold from one to the other, at some agreed value. Just like any other sale. And you notify the CAA.
Or the new company can purchase the old company. There are conventionally at least 2 ways to do this: buy the business as a whole, or just buy its assets. There are probably issues with a German company owning a UK company, but the asset sale route should be easy.
In terms of aviation, this is all a complete non-event. Of course you may have any number of reasons for leaving the UK, etc.
Of course you may have any number of reasons for leaving the UK, etc.
Yes. The company is consulting and therefore service industry. We need the EU framework as most customers are overseas.
We can pay taxes elsewhere when we are not welcome anymore.
