Update on cruising in French waters and the CERFA Cabotage declaration form
On 20th January, following a request from MYBA, the Director of the Ports of Nice & Cannes, managed by the French Riviera Chamber of Commerce and Industry, Franck Dosne, kindly invited representatives of several Superyacht/Captains’ associations (MYBA, PYA, IYM, GEPY & ECPY) to meet in Nice with the Alpes-Maritimes’ Director of Maritime Affairs (Directeur des Affaires Maritimes, A-M) to discuss the newly introduced CERFA Cabotage Declaration form.
In theory, Captains of large yachts operating commercially are required to submit this form to the authorities 72 hours prior to undertaking any cruises in French waters, attaching certain documentation translated into French and holding further documentation on board for possible inspection. MYBA was accompanied by its French legal counsel, Freddy Desplanques of Ince & Co, France, in an effort to provide as much industry input as possible, and examine all possible approaches to these questions, including the economic impact of applying such measures.
Those present submitted their concerns regarding these developments and insisted on precise clarification on several points which will now be referred to the tax authorities in Paris (Direction Centrale) in the hope that a positive dialogue can be established. A letter will also be sent shortly to the DDTM (Direction Départementale des Territoires et de la Mer) in Paris asking for responses and for some of the incoherencies to be abandoned, and finally, proposing a possible solution.
In the interim, the good news is that we were informed that these new measures will not be immediately applicable because the structure to implement them is not yet in place.