Operating as a ltd company is IMHO not relevant, but renting is.
I was on G-reg 2002-2005. The plane was ltd company owned and the company (which I owned 100%) rented the plane (a) to myself, and (b) to a few others.
Back then the regs clearly required Public Transport CofA maintenance for renting out.
My view is that (a) alone is the same thing. But it's a grey area in practice; many private owners own the plane via a company and get the company to invoice them for flying (which is a standard component in the defence against Benefit in Kind, which always arises on a ltd company owned plane) yet they run the engine "on condition" etc. But what is "renting"? If the owner didn't generate that "rental invoice" but just flew the plane whenever he wanted to and got an equivalent adjustment done via the Director's loan account at the end of the financial year, that clearly isn't "renting" then.
IMHO, in the scenario described i.e. multiple pilots, if the plane is "rented" then you have to overhaul.
I would overhaul anyway at 2k. I know of the standard arguments against taking apart a "working" engine but you never know what is brewing inside... if (like most) you don't do oil analysis then you have very little idea of the internal condition.
If you were N-reg then you could rent a plane out while maintaining under FAR Part 91, with no special requirements. There is a potential 100hr check but this is required only for paying passengers, and if you train others in your plane.
Last edited by peterh337; 30th Sep 2012 at 11:01.