This document summarizes international aircraft operations and procedures for operating in the European Union. It discusses considerations for outbound flights from the US such as documentation requirements. It also discusses considerations for inbound flights to Europe such as higher fuel costs, payment methods, and obtaining overflight and landing rights. Finally, it explains the differences between cabotage (commercial domestic flights within a country) and importation for operating an aircraft in Europe. Penalties for unauthorized cabotage include customs duties and impoundment.

1. International Aircraft Operations
Operating Procedures for the European Union
Ari Good JD LLM
www.goodattorneysatlaw.com/aviation
(c) Good Attorneys At Law, P.A. 2012

2. Fundamental Framework
• ‘Outbound’ Considerations
• ‘Inbound’ Considerations
• How best to operate in the EU?
Importation vs. Cabotage
www.goodattorneysatlaw.com/aviation
(c) Good Attorneys At Law, P.A. 2012

3. ‘Outbound’ Considerations
• Careful planning required
2. Aircraft / Trip Documentation – Airworthiness Certificate, “White Slip” FAA
Registration, “Journey Log Book”, Radio Station License, FCC Restricted Radio
Operator’s License, Aircraft Operator’s Handbook (weight, balance & noise),
Passenger List, Cargo List
4. Personal Documentation – Passport (w/ some exceptions for Bahamas /
Caribbean), Visas, Immunization Records
6. Legal Documentation – Proof of Insurance, Letter of Company Authority, LOA
(Letter of Authorization from FAA Administrator) – Specifies technical
requirements
8. CCM (Cold Cash Money)
Where to find it?
• International Flight Information Manual (IFIM), at www.faa.gov
• Country-specific requirements, at www.faa.gov/ats/aat/ifim/index.htm
www.goodattorneysatlaw.com/aviation
(c) Good Attorneys At Law, P.A. 2012

4. ‘Inbound’ Considerations
• Overflight and Landing Rights
• Practically – Could take up to four weeks to receive various rights and permissions.
Instead, go with a Flight Planning Firm – A company that specializes in quickly
assembling necessary rights, licenses or permits, customs support. Helpful, but
always check their work.
• Substantially Higher DOC
• Fuel - Fuel about 2x U.S. at the pump. Added excise and other taxes can raise price
as high as 4x U.S. price!
• Method of Payment – Europe has wide acceptance of U.S. based credit card
companies, but be prepared with cash or other internationally accepted method of
payment
Where to find it?
1. NBAA Directory of Member Companies, Aircraft & Personnel
2. “Blog” at www.nbaa.org/member/iob/iobresearch.htm
(c) Good Attorneys At Law, P.A. 2012

5. Cabotage & Importation
• Two Methods
1. Cabotage
2. Importation
• What is Cabotage?
“Carriage of passengers or goods between two points within the territory
of the same nation for compensation or hire” – i.e. Commercial Use
(f) Chicago Convention on International Civil Aviation of 1944 – The “Eighth
Freedom of the Air”;
(g) EU defines “Commercial Use” very broadly – “transportation…for
remuneration or ‘in the framework of the economic activity of an
enterprise’”;
(h) Used to protect national security, protect domestic industry;
(i) Carriage of personnel other than passengers present on the inbound flight.
Where to find it?
Country-by-Country Aeronautical Information Publication (not exhaustive)
(c) Good Attorneys At Law, P.A. 2012

6. Cabotage & Importation
• Penalties for falling outside
permissible Cabotage bounds
1. Subject to Customs Duties and /or VAT (up to 18% or
more!)
2. Impoundment
• Importation
2. Governed by EC Customs Code 2454/1993; Istanbul
Convention on Temporary Admission;
3. Allows temporary or permanent “admission” into EU
jurisdiction – Aircraft treated as an EU aircraft;
4. Still subject to EU aviation regulation within its borders –
Limited to six months out of twelve
(c) Good Attorneys At Law, P.A. 2012

7. Contact Us
• Ari Good, JD LLM (Taxation) –
Counseling clients in aircraft tax
matters, international aviation tax
planning and aircraft transactions.
• 877.771.1131
• www.goodattorneysatlaw.com
• Plan early, plan correctly