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Restrictions on basing EU-reg aircraft outside their country of registry?

I am currently in contact with a prospective TB20 (ICAO CofA) owner, non UK, who is looking at an aircraft which I believe will require a “mailbox” maintained in the country of registration. In practice this needs to be a person, and he/she will obviously

  • want to be paid for it, and
  • have you over a barrel because (unlike an N-reg trust) this arrangement cannot be formalised overtly

Are people here aware of such requirements?

I vaguely recall a G-reg needs a UK address registered at G-INFO (can anybody find any exceptions there?) but they probably don’t care since no correspondence of note takes place (you get some free rags like GASIL/GASCO mailed there) so it could literally be a mail forwarding service.

What about Germany, Belgium, Netherlands, France?

Administrator
Shoreham EGKA, United Kingdom

I am pretty sure I have seen owners with addresses in France or Belgium on G-INFO, so I am not certain you are correct.

Darley Moor, Gamston (UK)

There are a few G-regs based at Belgian fields but as far as I know they are all on a Permit to Fly. One owner (a hangar neighbour, actually) told me that it is becoming more and more difficult to keep up the status, though, the LAA have a rule to not allow it and are doing their best to enforce it. And I have no knowledge of any certified G-reg over here.

EBZH Kiewit, Belgium

In the past, a lot of people complained about the Part M stuff requiring e.g. the servicing to be done in France if the plane was F-reg. This now seems sorted out and isn’t an issue anymore.

But the requirement for a local-address “registered keeper” (the UK term, with cars) could still screw somebody. It’s OK if you have a family member “back home” who can act as the mailbox…

Administrator
Shoreham EGKA, United Kingdom

G-reg definitely does not require a UK address in G-INFO, as I don’t have one. My maintenance organisation and CAMO are British, though.

As to other countries, even if a local address is required, I am sure it’s easier and more convenient to establish a legal entity for that purpose than to register fictitious ownership by a physical person. It may even bring some tax advantages if planned properly.

LKBU (near Prague), Czech Republic

i can confirm with G reg you only must be a resident of the EU
in Belgium you need to have a registrate adress (i know as i was looking into buying on OO reg airplane and wanted to keep it on OO until next annual was due = a nightmare)
in the netherlands you need to have a “postal” contact adress

fly2000

If you need a postal address, in Belgium or The Netherlands, what sort of activities does the owner of that address need to do? Could it be just a mail forwarding company, and could the fact that it is just a mail forwarding company be obvious? Incidentally is this different between a CofA and a homebuilt?

After all, with a contact address, all the CAA can possibly do is to send mail there – which will get forwarded to you living in Kathmandu. They are not going to visit the address. And the only way they could tell you are living in Kathmandu is by looking at the stamp, which would require above average due diligence, and would be avoided by getting it franked. (I sometimes wonder if the taxman looks specially for franked envelopes, to see which businessmen are using their office franking machine for their private mail )

So why

i know as i was looking into buying on OO reg airplane and wanted to keep it on OO until next annual was due = a nightmare

would this have been a nightmare? I can see why you wanted to keep it OO- till the next Annual, because the best time by far to change the registry is at an Annual.

But a requirement for a postal address is very different from a requirement for the owner of the aircraft to be resident in the country of registry.

Also does a full-CofA type registry transfer from say Belgium to say Germany involve an Export CofA (which it does when going N-reg, unless you can get a specific DGAC letter which is the route I followed).

Administrator
Shoreham EGKA, United Kingdom

A registered address is a different thing than any postal address, no? FWIW (possibly not much) in several Continental countries you need a local residence permit to register a car. The car registration letters then reflect the address on your residence permit. I have no idea why that system exists but anyway there would be a precedent for requiring an aircraft owner to supply a residence permit with his local registered address.

Last Edited by Silvaire at 05 Feb 21:27

Hi Peter

I have checked with the Dutch CAA and they wrote to me that you can be the owner of a Dutch registered aeroplane and not live in the Netherlands but you do need a contact person over in the Netherlands so they can communicate with you.

I asked if this was applicable to EASA CofA and homebuilts.

I suggest that anyone who wants to go this route satisfies themselves that their personal circumstances and planned management of ownership and registration is compatible with the regulations as applied by the regulator relevant to the object of their aviation desires.

Hope that helps.

Many thanks Flyin’Dutch’ – that’s a useful piece of data.

So, it appears, there is nothing illegal in using say a commercial mailbox service – in this case. Presumably one without a “P.O. Box XXXX” in the address

Administrator
Shoreham EGKA, United Kingdom
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