These regulations lack clarity on some points. For example, they need a registration from the Central Bank of Brazil, which is normally required for the transfer of foreign currency; However, the central bank`s rules do not always require such registrations. They are not required for agreements lasting less than 360 days.B. Therefore, if an exchange contract is less than 360 days, the airline may not meet this requirement. In addition, the central bank requires the registrant to indicate a certain amount of fixed payments. However, in the case of exchange agreements, the parties rarely know in advance how many times the exchange will use the aircraft. As a result, trade may not meet this requirement, even for exchange contracts lasting more than 360 days. However, the main problem with the 2013 regulations is that they do not specify whether an exchange agreement involving an aircraft registered in another jurisdiction can be exchanged to allow a Brazilian airline to operate it. The origin of the exchange idea needs to be explained. If your aircraft is not on a commercial certificate, you cannot normally use it to allow transport for compensation.
You could rent it to someone who provides their own pilots, but if you equip the aircraft and you even have a crew member and compensation, the FAA will call the flight commercial. Traditionally, this was also the case when compensation was not money; This could have been useful to any passenger, including your passenger, who will provide you with transportation on their plane. In other words, trading time on your plane for time on someone else needs a commercial certificate from the FAA. But in 1972, when the agency realized that these time trading agreements were in progress, it decided to legalize them. Since the FAA used the term ”time-sharing” to refer to a completely different agreement, it chose to characterize the arrangements as ”exchange.” According to FAR 91.501, ”a person in an exchange contract rents his plane to another person in exchange for the same time, if necessary, on the other person`s plane, and no charges, charges or charges are charged.” It sounds simple. But say I`m trading time on my Global 5000 for time on your Cessna Bravo Citation. The hourly operating costs (not to mention the fixed fee) are almost four times higher for my overall than for your Bravo, so if we act every hour, you pretend to be a bandit.