Buying a Learjet 75 from Poland for a Brazilian buyer: USD 7 million
Case study · Aviation law · Key matter · 2022
USD 7m
Purchase price of a 2015 Bombardier Learjet 75 bought from a Polish owner by a private buyer from Brazil, closed through an escrow agent in the United States.
A private buyer from Brazil agreed to buy a business jet entered in the Polish civil aircraft register. Dudkowiak & Putyra’s aviation law practice acted as the buyer’s counsel in Poland: from the due diligence of the aircraft and the negotiation of the transaction agreement to the supervision of the closing and the removal of the jet from the Polish register for export to Brazil.
- Poland Seller · aircraft
- United States Escrow agent
- Brazil Buyer
Written by Michał Puk · Reviewed by Maksymilian Cudnik
Published: 22 October 2026
Michał Puk · Barrister (adwokat), Supervising Partner · your contact for this matter
[email protected] · +48 22 300 16 74 · We reply within 24 hours with a scope and a timeline.
Key facts
- Client
- Private buyer from Brazil
- Our role
- Buyer’s counsel in Poland: due diligence, agreement, closing
- Aircraft
- 2015 Bombardier Learjet 75 with two Honeywell TFE731 engines
- Purchase price
- USD 7mheld by an escrow agent in the US
- Security
- Price released only when the closing conditions were met
- Registers checked
- Polish CAA, pledges, treasury pledges, International Registry
- Jurisdictions
- Poland · Brazil · United States
In short: Dudkowiak & Putyra acted as Polish counsel to a private buyer from Brazil in the USD 7 million purchase of a 2015 Bombardier Learjet 75 from a Polish owner, covering the due diligence of the aircraft, the purchase agreement, the closing through a US escrow agent and the removal of the jet from the Polish register.
The team behind the deal
An aircraft bought across three jurisdictions needs lawyers who can read Polish registers, negotiate an English-language transaction agreement and work to a closing date set by the parties to the transaction.
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Led the transaction and represented the buyer in Poland: due diligence, negotiation of the transaction agreement and supervision of the closing.
- Aviation
- Contracts
- M&A
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Maksymilian Cudnik Attorney (radca prawny) · Counsel
Commercial and transaction lawyer in the team that advised the buyer on the transaction documents.
- Commercial contracts
- Cross-border deals
- PL · EN · DE
Background
In 2022 a private buyer from Brazil agreed to buy a 2015 Bombardier Learjet 75 from a Polish company. The jet was entered in the Polish civil aircraft register and had to leave it before export to Brazil.
- PLPolandAircraft on the Polish register; seller based here
- USUnited StatesEscrow agent holding the price and the closing documents
- BRBrazilBuyer and the destination register under the Brazilian aviation authority
The parties agreed a purchase price of USD 7 million, held by an escrow agent in the United States until closing. The buyer instructed us through his lawyers in Brazil to protect his position under Polish law.
The challenge
A business jet changes hands across borders only once the money, the title and the registration move together. The buyer needed certainty on four points:
- 01Legal title, liens and encumbrancesDue diligence of the seller’s title and of any pledges, tax liens or international interests on the airframe, the two engines and the auxiliary power unit.
- 02A deal across three countriesRegulatory questions from both the Polish and the Brazilian perspective, with the price secured by an escrow agent in the United States.
- 03A complex transaction agreementMany conditions, contractual sanctions and clauses protecting the interests of each party, to negotiate and draft, and then to supervise in performance.
- 04Deregistration and export outside the EURemoval of the jet from the Polish civil aircraft register, an export certificate of airworthiness accepted by Brazil, customs export and VAT, all before the escrow could release the price.
Buying or selling an aircraft in Poland?We reply within 24 hours with a scope and a timeline.
Our role
We made sure the buyer knew what he was buying and when he could safely pay. Six stages, from the regulatory analysis to the closing.
Click a stage to see what we did at each step of the purchase.
Stage 1 · Regulatory analysis
We analysed the regulatory and aviation-law requirements of an international aircraft sale from Poland to Brazil, working alongside the buyer’s lawyers in Brazil.
Stage 2 · Due diligence of the aircraft
We reviewed the jet’s file at the Polish Civil Aviation Authority and obtained certificates from the register of pledges and the register of treasury pledges for the airframe, both engines and the auxiliary power unit. Our red-flag report found no pledges and no tax liens.
Stage 3 · Transaction agreement
We negotiated and prepared the aircraft purchase agreement and the other transaction documents: conditions for closing, contractual sanctions and clauses protecting the buyer’s interests.
Stage 4 · Escrow in the United States
The price and the signed closing documents were held by an escrow agent in the US. We prepared the Polish-law documents and worked through the closing checklist with the parties.
Stage 5 · Deregistration and export
We checked the deregistration from the Polish civil aircraft register, the export certificate of airworthiness issued for Brazil, the customs export and the 0% VAT on export.
Stage 6 · Closing
We supervised the performance of the agreement. Once we confirmed that the Polish documents and registers were in order, the escrow agent could release the USD 7 million price.
The result
USD 7,000,000
Purchase price closed through the US escrow, with the jet removed from the Polish register and cleared for export to Brazil.
Click a document in the closing pack to see what it proved to the buyer.
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01Register certificatesRegister of pledges and register of treasury pledgesNo pledges and no tax liensClear for the airframe, both engines and the auxiliary power unit.
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02International Registry searchPriority search certificatesNo international interestsNothing registered against the aircraft before the buyer took title.
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03Warranty bill of saleNotarised and apostilledTitle passed to the buyerReleased by the escrow agent at closing.
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04Certificate of deregistrationPolish Civil Aviation AuthorityThe jet left the Polish registerReady to be entered in the Brazilian one.
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05Export certificate of airworthinessIssued for BrazilAirworthy for the destination countryDeviations pre-accepted by the Brazilian aviation authority.
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06Customs and VAT documentsExport outside the EUExport confirmedSupporting 0% VAT on the sale.
Talk to us
Preliminary case review
Buying or selling an aircraft in Poland? Talk to the team that closed this deal.
We review the transaction agreement, the registers and the closing documents. We reply within 24 hours with a scope and a timeline.
Talk to the team
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Michał PukBarrister · Supervising Partner
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Maksymilian CudnikAttorney · Counsel
