Since N-reg planes generally need to be placed in a US-based trust, how does owning a N-reg plane by an European company work? As in, what are the key words I need to bring up with my accountant when talking about it? I would want the plane to be a company asset for tax reasons, both initial-purchase wise and in regards to the ongoing costs, the way I would be able to do with an EU-reg one.
It is exactly the same as an EU reg but the aircraft is formally held via a US trust. Other than cost, the US trust is irrelevant.
In the UK, the tax authority regards these trusts as transparent, so if ABC Ltd buys an N-reg plane for 200k, and it is held via say an SAC trust (i.e. ABC Ltd is the beneficial owner, or “trustor” in US-speak) then the tax situation is the same as if ABC Ltd bought the plane directly.
You can apply the normal capital allowances (depreciation for tax purposes, crudely speaking), etc.
The usual gotchas also apply equally. If all airborne time is for the business then there should be no personal tax issues (no Benefit in Kind) etc etc… and these are reasons why – in the UK – a company owned plane is a risky proposition IF there is any personal usage. We have had other threads covering this.
Been there, done that
Other countries may have different tax treatment of trust-held company assets.