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debonair
Topic Author
Posts: 4865
Joined: Sat Jan 03, 2004 10:50 pm

Malta - flag of convenience

Sun Aug 16, 2020 11:10 am

Hi to you all!

More and more airlines setting up an affiliate company in Malta - but how does it work in terms of operations and safety? Anyone with more knowledge and insight?
There are different airlines with just one single aircraft registered in Malta, e.g. Freebird Europe 9H-FHB, but there main fleet elsewhere.Is the company obliged to have a full operational HQ in Malta (with OPS, Crewing etc.) - or is this just a "letter box" and the operations, crew rostering are handled elsewhere - like in Turkey? Also, AFAIK, the aircraft, in this case 9H-FHB, only once visited Malta for acceptance by the Maltese CAA. So how does the regulator control the fulfilment of maintenance, paperwork and duty hours, as the a/c is based abroad and only registered in Malta?
On top, as nearly every month new airframes come online on the Maltese register, let alone Malta Air by Ryanair, how does this small CAA cope with the demand? The employment numbers must have been exploded by the Maltese CAA to cope with the work...
 
johns624
Posts: 7328
Joined: Mon Jul 07, 2008 11:09 pm

Re: Malta - flag of convenience

Sun Aug 16, 2020 11:57 am

The cruise companies are currently finding out that flags of convenience can come back to bite you in the ass. They are mainly US companies with US employees in the HQ but didn't get anyCovid-19 subsidies because they are registered offshore.
 
MIflyer12
Posts: 13453
Joined: Mon Feb 18, 2013 11:58 pm

Re: Malta - flag of convenience

Sun Aug 16, 2020 12:05 pm

debonair wrote:
Is the company obliged to have a full operational HQ in Malta (with OPS, Crewing etc.) - or is this just a "letter box" and the operations, crew rostering are handled elsewhere - like in Turkey? Also, AFAIK, the aircraft, in this case 9H-FHB, only once visited Malta for acceptance by the Maltese CAA. So how does the regulator control the fulfilment of maintenance, paperwork and duty hours, as the a/c is based abroad and only registered in Malta?
On top, as nearly every month new airframes come online on the Maltese register, let alone Malta Air by Ryanair, how does this small CAA cope with the demand?


Separate out what's done at the national level vs. done/regulated by the EU.
 
airbuster
Posts: 544
Joined: Fri Mar 30, 2007 12:43 am

Re: Malta - flag of convenience

Sun Aug 16, 2020 12:15 pm

On a related note, I recently discovered that San Marino also has a CAA with some private jets registered. AFAIK they don’t even have an Airport there (if you don’t count Rimini).
 
BelowTheWing
Posts: 19
Joined: Sun Dec 15, 2019 5:18 am

Re: Malta - flag of convenience

Sun Aug 16, 2020 12:47 pm

Most airlines register a European subsidiary in Malta for tax reasons. I'll explain soon. But first to answer your question. In my previous company, we were doing the handling for some airlines with Maltese subsidiaries, including Freebird Europe and Corendon Europe. Legally speaking, they are their own airline with their own headquarters. However, operations and crewing are mostly controlled by the mother company's departments. The fleets are also mixed, meaning that Turkish and Maltese aircraft can fly for both airlines as deemed necessary. Corendon especially regularly utilizes Turkish aircraft for their Intra-European flights. Freebird appears to be a bit more conscious but also sometimes uses Turkish aircraft. As for the maintenance part, it's quite simple actually. CAA usually just check, whether aircraft arriving and departing from their country are in good shape, regardless of country of registration. When it comes to a big check, airlines simply can fly the respective aircraft to Malta. Which is also quite convenient with Lufthansa Technik Malta just around.

And for all this, there's a very simple reason: Freedoms of the Air. It's much easier for a European company to secure deals with all-inclusive touristic companies and/or charter services as they will be granted rights to fly in and out of the EU as they want. They are a European company after all. Corendon Europe, for example, is heavily expanding in Germany (or at least intended to so so pre-Corona) with their own bases and considerably more flights to non-Turkish destinations than before.
 
fcogafa
Posts: 1559
Joined: Fri May 16, 2008 4:37 pm

Re: Malta - flag of convenience

Sun Aug 16, 2020 12:55 pm

airbuster wrote:
On a related note, I recently discovered that San Marino also has a CAA with some private jets registered. AFAIK they don’t even have an Airport there (if you don’t count Rimini).


Currently 146 Biz jets on the San Marino register, 244 on the Isle of Man register and 163 on the Malta register!
 
User avatar
InnsbruckFlyer
Posts: 442
Joined: Sat Nov 25, 2017 1:35 pm

Re: Malta - flag of convenience

Sun Aug 16, 2020 1:41 pm

fcogafa wrote:
airbuster wrote:
On a related note, I recently discovered that San Marino also has a CAA with some private jets registered. AFAIK they don’t even have an Airport there (if you don’t count Rimini).


Currently 146 Biz jets on the San Marino register, 244 on the Isle of Man register and 163 on the Malta register!


Quite a few MEA A320/321s are also registered in San Marino.
 
DUSZRH
Posts: 389
Joined: Thu Jan 05, 2017 12:17 am

Re: Malta - flag of convenience

Sun Aug 16, 2020 8:41 pm

fcogafa wrote:
airbuster wrote:
On a related note, I recently discovered that San Marino also has a CAA with some private jets registered. AFAIK they don’t even have an Airport there (if you don’t count Rimini).


Currently 146 Biz jets on the San Marino register, 244 on the Isle of Man register and 163 on the Malta register!


IoM used to be ex-EU. If you want to understand the reasons behind it, there was a report of Lewis Hamilton and his biz jet.
 
User avatar
aemoreira1981
Posts: 4264
Joined: Mon Jan 09, 2017 12:17 am

Re: Malta - flag of convenience

Sun Aug 16, 2020 8:57 pm

airbuster wrote:
On a related note, I recently discovered that San Marino also has a CAA with some private jets registered. AFAIK they don’t even have an Airport there (if you don’t count Rimini).


How does that work with respect to Middle East Airlines? Their leased A320s, and now their new A21Ns which appear to be owned, are on the San Marino registry (their owned A320s, and their A332s, which are all owned, are on the Lebanon registry). At one time, all of the Middle East Airlines' fleet was registered in France.

Also, Hi Fly tends to split its fleet between the Portuguese and Maltese registries...why have a separate AOC for a small outfit? For Ryanair, I suspect that their Maltese AOC is for labor issues.
 
bennett123
Posts: 12549
Joined: Sun Aug 15, 2004 12:49 am

Re: Malta - flag of convenience

Sun Aug 16, 2020 9:02 pm

How does Malta regulate all of these additional aircraft, many of which will never be in Malta?.
 
User avatar
TS-IOR
Posts: 3778
Joined: Mon Oct 08, 2001 9:44 pm

Re: Malta - flag of convenience

Wed Aug 19, 2020 1:38 am

It's EU regulated and everything safety wise is JAR and done the proper way. For maintenance and operations purpose it is not required to have personnel based at MLA. All they need to show is a contract with a certified MRO somewhere in the world and a local FBO and/or OPS agent for everyday needs if the airplane is going to fly in and out regularly. Same as airplanes registered in Ireland with the difference that lessors are not operators and have no operational requirements. Most of flights are done under lessee authority or special authorizations.
 
User avatar
TS-IOR
Posts: 3778
Joined: Mon Oct 08, 2001 9:44 pm

Re: Malta - flag of convenience

Wed Aug 19, 2020 1:49 am

BelowTheWing wrote:
Most airlines register a European subsidiary in Malta for tax reasons. I'll explain soon. But first to answer your question. In my previous company, we were doing the handling for some airlines with Maltese subsidiaries, including Freebird Europe and Corendon Europe. Legally speaking, they are their own airline with their own headquarters. However, operations and crewing are mostly controlled by the mother company's departments. The fleets are also mixed, meaning that Turkish and Maltese aircraft can fly for both airlines as deemed necessary. Corendon especially regularly utilizes Turkish aircraft for their Intra-European flights. Freebird appears to be a bit more conscious but also sometimes uses Turkish aircraft. As for the maintenance part, it's quite simple actually. CAA usually just check, whether aircraft arriving and departing from their country are in good shape, regardless of country of registration. When it comes to a big check, airlines simply can fly the respective aircraft to Malta. Which is also quite convenient with Lufthansa Technik Malta just around.

And for all this, there's a very simple reason: Freedoms of the Air. It's much easier for a European company to secure deals with all-inclusive touristic companies and/or charter services as they will be granted rights to fly in and out of the EU as they want. They are a European company after all. Corendon Europe, for example, is heavily expanding in Germany (or at least intended to so so pre-Corona) with their own bases and considerably more flights to non-Turkish destinations than before.


When Corendon TK is subbing for Corendon EU there should be a wet or ACMI or damp lease agreement onboard otherwise there may be violation of cabotage or bilateral agreements. SunExpress did so too, but no more as the German subsidiary has now gone burst.

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