Legal title
A dedicated SPV holds the aircraft. Its jurisdiction, substance and governance are chosen for regulatory positioning — not for a headline tax rate.
Designing SPV ownership, jurisdiction selection and VAT positioning for aircraft acquired and operated in the EU — built around how the aircraft actually flies, not around a registry brochure.
Discuss your structureAircraft ownership in Europe sits at the intersection of corporate law, aviation regulation, VAT positioning and operational licensing. A generic holding structure does not survive here: ownership has to align with EU aviation rules, registry practice, and tax treatment tied to the aircraft's actual use and base of operations.
In practice, the structure is driven less by ownership efficiency and more by where the aircraft is based, operated and maintained — from hubs such as Nice (LFMN), Geneva (LSGG), Farnborough (EGLF), Malta (LMML) and Luxembourg (ELLX) to secondary bases across Spain, Italy and Germany.
Our role is to make the legal structure and the operational reality say the same thing — so it holds when a tax authority or aviation regulator looks at it years later.
At its core, the structure holds legal title through a dedicated SPV, then cleanly separates ownership, operation and beneficial use. That separation is what gives regulatory alignment and operational flexibility across EU jurisdictions.
A dedicated SPV holds the aircraft. Its jurisdiction, substance and governance are chosen for regulatory positioning — not for a headline tax rate.
Where an AOC is involved, operation is placed with an operator that can demonstrate genuine control, keeping private and commercial use properly delineated.
Who actually flies the aircraft, and on what terms, is documented and aligned with the leasing chain — so the paperwork matches the flight logs.
Dry or wet lease arrangements connect the three roles. Each link needs a real commercial rationale, or the whole chain becomes challengeable.
Ownership structuring is rarely urgent until it is. These are the points at which getting it right — or correcting it — has the largest financial consequence.
Determining ownership vehicle, jurisdiction and VAT position before the purchase agreement is signed.
Risk if skipped: VAT position fixed by default, hard to unwind later.Assessing VAT exposure, registration options and the point and basis of import.
Risk if skipped: import reassessed on actual use, not entry point.Planning operation through an AOC or making the aircraft available for charter.
Risk if skipped: exemption denied if commercial use is not evidenced.Owner based outside the EU but intending to operate the aircraft within Europe.
Risk if skipped: mismatch between residence, registry and operating base.An existing structure that needs review because usage has changed, the aircraft has been re-based, or the arrangement predates the current regulatory and audit climate.
Risk if skipped: a structure that worked on paper years ago may no longer survive an operational-reality test.Structuring is not open-ended advice. Each phase produces a concrete document you can act on, share with counsel, or put in front of a bank.
A written read of the current or planned structure against EU VAT and regulatory risk.
SPV configuration, jurisdiction, leasing model and AOC alignment, each choice reasoned.
Incorporation, operator coordination, legal documentation and banking alignment.
Periodic re-check against changing flight activity, ownership and regulatory practice.
Choosing where the SPV sits is about how that jurisdiction interacts with the VAT Directive, EASA recognition, import mechanics and substance requirements — for this aircraft and this operating pattern.
Each interacts differently with VAT Directive 2006/112/EC (notably Art. 148 and Art. 56), local rules on commercial vs. private use, import VAT deferral, customs procedures (temporary admission, inward processing relief) and EASA Basic Regulation (EU) 2018/1139. There is no single "best" jurisdiction — only the one that matches the aircraft's real use.
A structure that is right on VAT but weak on substance fails just as completely as one that is wrong on both. We design against all four from the start.
Exemption for international transport is not granted by contract type. Flight activity, passenger profile and genuine arm's-length charter revenue decide it.
An AOC operator must demonstrate effective control. Nominal operator arrangements collapse the private/commercial distinction.
A registered office is not substance. Decision-making location, management and genuine activity determine whether the SPV is respected at all.
If a tax benefit was a principal purpose, benefits can be denied regardless of formal compliance with each individual step.
Four questions to open the conversation. If it's something we can help with, we'll come back with specific questions about jurisdiction, lease structure and operating history.