I am giving serious though to upgrading to an N Reg Jetprop PT6 35 or DLX in the next few months. I have been flying a PA46 Malibu Mirage for the last 6 years, and before that a TBM 700 for several years. My wife is encouraging me to head for a turboprop again as we are planning to move to a warmer EU country in a couple of years, but still maintain a UK base, so speed, jetA availability, grass field capability and sub 2t cost issues are at the forefront.
Two options:
Upgrade my 2006 Mirage. Pros: new engine, I have invested tons in keeping all the complex systems well maintained (pressurisation, hydraulics etc etc), I know and like the avionics (Avidyne and good navigators and AP). Cons: time (Rocket Engineering wont even think about starting before xmas) and $700k cost
Purchase a mid time used Jetprop. Pros: get it soon (not getting any younger 63), cost. Cons: uncertainty on real quality of engine and systems, avionics.
In both cases I am really confused about import duty/VAT issues and would appreciate any advice.
My Mirage was imported into the EU via the UK in 2012 years ago and has the EU Certificate/C88.
If I send it to the US for the Jetprop conversion will I have to pay UK Import Duty/VAT on the cost of the conversion, or might this fall under the exemption for aircraft parts I have read about? The aircraft was in the UK on Brexit day. Does this mean that if I rebased it in the EU in a couple of years I would have to pay then EU Import Duty on its full market value then? Would it lose its UK import duty paid status then?
If instead a bought an existing EU based used Jetprop now and use it in the UK, I assume I would have to pay UK import duty, correct?. When I then move it back to the EU in a couple if years do I have to pay EU duty then, or would the prior free circulation/C88 certificate still be valid?
Thank you very much for any and all wisdom!
If I were you I would opt for upgrading my aircraft. Pros: you know the plane and the condition of all the systems, you’ll get new engine with 3600 TBO and total resale value of your aircraft will be increased for $700k (according to current market state you won’t lose anything with this investment), you’ll have hard time finding mid-time JetProp similar age as your Mirage with good avionics and good interior. Cons: lead time plus ferry flights cost (can be fun so you don’t have to see it as bad thing 
).
Does the upgrade not affect the panel layout or does it keep the same?
I would also suggest going with the known airframe. I understand the main con for you is actually time, but the time you will waste getting your new airplane to your current standard will easily be more than the couple of months you’ll be plane-less while they do the mod.
Also , as @Emir sais: you’ll miss the pèrfect excuse for one two transatlantic crossings in northern lights season! : priceless!
As to customs, I have no clue on the Brexit situation.
I know exactly about the EU situation: you can send your free-EU-status plane out of the EU for upgrade and you will pay zero import taxes or duties on the way out or back. I do that all the time with large aircraft, although I admit I never did that with full engine upgrades. The only time it would be declared is if you really want a record of import of the engine, and then ytou have to do it right and still pay zero duties, but VAT may be payable depending on your importer status…I would not bother.
You will only pay applicable local taxes in the US for the mod, and that is state-dependant..where is Rocket Engineering?.
Another important caveat (though immigration, not customs) is you (and those onboard a private flight) need a US C1/D crew or B1/B2 business/visitor visa for the ferry flight . In the COVID world, you will also need a US DoS National Interest Exemption (NIE) if on a B1/B2 visa. C1/D does not need a NIE.
Buckerfan wrote:
am giving serious though to upgrading to an N Reg Jetprop PT6 35 or DLX
The DLX is the -35 and the -21 is the DL / the -35 is the one that you would want, having said that there is nothing wrong with the -21 its just the -35 has more power at altitude.
I would do what Emir and Antonio suggest … convert your airframe as you know it and you will also be getting a new engine.
If you send me an email I will send you a copy of the Rocket Eng Invoice from when it was converted, it will give you an insight into the scope of the work done and any additional items that you may not have considered
Or I can fly into your strip ……
you can send your free-EU-status plane out of the EU for upgrade and you will pay zero import taxes or duties on the way out or back
The engine installation is duty free but you have to pay import VAT on the upgrade. Same in the EU or post-brexit UK. Same with engine overhauls etc done in the US. Is a whole airframe different?
Whether anybody will notice if you don’t declare it, is another matter.
If the US wasn’t so far away and the flight there wasn’t so hazardous and needing so much preparation and equipment, Europe’s avionics and other refit business would be immediately dead because you can get stuff done there for much less money, and the import VAT due would be unenforceable.
I also fully agree with keeping your airframe. You know it inside out, you put the avionics, you will come back with a famliar cockpit and a brand new engine.
Any used airplane will come with hidden surprises or things you don’t really want in terms of avionics, which then will cause another upgrade and more money and down time.
The longer I look at used planes, the more I come to the conclusion that not that much beats an airplane you know inside out when the question arises upgrade your plane or go for one which is closer but not quite there where you want to be.
Peter wrote:
The engine installation is duty free but you have to pay import VAT on the upgrade.
I am so naive about this stuff. What is the difference between import VAT and duty. I thought when you import a plane to the UK/EU you just pay VAT and thats it. Is there a separate import duty payable as well?
Buckerfan wrote:
I am so naive about this stuff. What is the difference between import VAT and duty. I thought when you import a plane to the UK/EU you just pay VAT and thats it. Is there a separate import duty payable as well?
Aicraft and parts are duty free or 0% duty rated but you pay VAT. So on a Jetprop upgrade you end up paying VAT on the 700k. I think many owners in the past did not do this as it is hard to detect for customs but it is clearly illegal and I know that at least Switzerland does audits on aircraft logs to see if there are any non declared jobs done abroad in there. If you want to do this properly I think you even have to declare the project before you export the aircraft to the US and then finish the procedure when it comes back. The German term for this is “Passive Veredelung” but I have no clue what it might be in English.
That is exactly my understanding, proven over several “US jobs”, various instrument repairs, and many others I know about.
No idea about “Passive Veredelung” but in general when you export something, to be worked on, and then re-imported, it can be a hassle to get Customs to tie the two up so you pay VAT only on the difference. It is much easier if you use the same shipper but of course in this case there is no shipper because it is a whole plane
Bear in mind that the US, unlike certain countries in Europe 
, is reluctant to issue undervalue (fake) invoices so you pay less VAT. They normally play it straight.
