3 ms·

Of course it's largely UK's own making. But EU surely didn't make it any easier. The VAT rules alone make it really difficult for small business to export to EU

by yread 6y ago

Of course it's largely UK's own making. But EU surely didn't make it any easier. The VAT rules alone make it really difficult for small business to export to EU. Each country has its own rules, thresholds and agencies. Compared to how easy is it for us in the EU to do business within EU it's crazy. That's why UK's own government recommends opening a subsidiary in the EU.

lottin 6y ago
Exporters don't pay VAT, importers do.
- yread 6y ago
  I admit I only looked into very quickly but it seems that UK business might need fiscal representatives in each EU country they do business with https://www.avalara.com/vatlive/en/vat-services/fiscal-representative-for-eu-vat.html https://www.avalara.com/vatlive/en/vat-services/fiscal-repre...
krona 6y ago
I was under the impression that most of the rule changes apply to the vast majority of cross-border B2C sellers in the EU from July: https://www.pwc.ch/en/insights/tax/new-ecommerce-eu-vat-rules-july-2021.html https://www.pwc.ch/en/insights/tax/new-ecommerce-eu-vat-rule...
corty 6y ago
The EU cannot make it any easier. Not because it wouldn't be possible at all, just that it would be suicidal for the EU or its politicians for several reasons. There are tendencies in several members to leave the EU or at least get rid of a few of the treaties. That means that leaving the EU in any really beneficial way for the UK would be strengthening the "leave" position in other members. And while the UK alone leaving is bad, more members leaving would be far worse. Then there is the topic of the UK rebate and the UK's special role in several treaties. The EU has always had to pamper the UK and the UK gave nothing but grief in return. It would have been political suicide for the EU leadership to give any impression of continuing to pamper the Brits in the Brexit treaties. Also, beneficial status for a non-member would weaken the EU position in treaties with other non-members such as Norway, Switzerland, Japan, Canada, etc. And then there is the problem of the UK being not really one country but a haphazard agglomeration of several territories. While Great Britain is somewhat uniform, Northern Ireland is special. There are several reasons for treating it in a special way in the Brexit treaty, like a looming civil war, a possible Irish veto, a possible smuggling route into the EU market. But it was clear from the start that this would hugely complicate matters. Same for Gibraltar and the channel Islands, French and Spanish vetoes looming, etc. I won't be surprised if the Brexit treaties don't hold forever. If the UK feels the squeeze of non-forthcoming trade with the rest of the world and diminishing trade with the EU, a more aligned status like the Norway/Switzerland model is possible. And I guess there will be a realignment of Northern Ireland and Gibraltar in some way, either towards a more unified UK or towards a weakened UK and Spanish/Irish unity, depending on what kind of hit the respective nations will take during COVID and the next few years. But from an internal EU point of view, the current Brexit treaty is the farthest the EU could have gone.
- rich_sasha 6y ago
  I suspect under the current model, Northern Ireland, and perhaps also Scotland, are untenable as parts of the Union. Northern Ireland is a political chimera that only existed in peace because you could pretend there is one Ireland under EU membership. I think as soon as Brexit pinches for good, NI and Scotland, both of which voted to remain in the EU, are out. Let’s just hope there isn’t another civil war in it.
  - joshuaissac 6y ago
    Scotland has far greater trade with the rest of Great Britain than with the EU, so it would be in their interests to remain in the British internal market and customs territory even if they gain political independence.[1][2] Northern Ireland remains in the EU Single Market, so the previous pretense of a unified Ireland within the EU can continue.[3] 1. https://www.ft.com/content/bbf2a097-37ff-42ea-8b22-c5662f0ae4be https://www.ft.com/content/bbf2a097-37ff-42ea-8b22-c5662f0ae... 2. https://www.gov.scot/publications/export-stats-scotland-2018/ https://www.gov.scot/publications/export-stats-scotland-2018... 3. https://www.bbc.com/news/uk-northern-ireland-55427004 https://www.bbc.com/news/uk-northern-ireland-55427004
    - rich_sasha 6y ago
      Brexit was an emotional issue, and I think this would be the same. 68% of Scots voted against Brexit, but the London government ignored that and piled ahead with fairly hard Brexit. Even the fishing industry, the prized jewel in the crown, got pretty screwed by Brexit. I don’t think the Irish arrangement is workable in practice. It’s trying to fit a square peg in a keg of dynamite. The Irish Protocol effectively puts it outside the British economic zone, since trade with Britain is effectively import and export, going thru customs and enormous red tape. Meanwhile, Ireland proper is just across the field. I think Northern Ireland will make it to its centenary but not much beyond.
    - kergonath 6y ago
      > Scotland has far greater trade with the rest of Great Britain than with the EU, so it would be in their interests to remain in the British internal market and customs territory The UK has far greater trade with the rest of the EU than with the rest of the world, so it would be in their interest to remain in the Single Market and Custom Union. I've always found it quite funny when English make this argument about Scotland. Particularly as the last independence referendum was won by the unionist side with a razor-thin margin, under the premises that the way for Scotland to stay in the EU was to stay in the UK. How is it that English nationalists are allowed to be unreasonable, but Scottish should not?
kergonath 6y ago
> The VAT rules alone make it really difficult for small business to export to EU But how would you do otherwise if one of the parties does not want any regulatory alignment and is barely cooperative? There was an easy way of solving this, which the British chose to ignore because they were not Norway.
belltaco 6y ago
UK had a big hand in crafting trade rules with third party countries while in the EU. They then refused the Switzerland arrangement, the Norway arrangement etc. and wanted to become a third party country. And now surprise pikachu face at the consequences of that.

by yread 6y ago

lottin 6y ago

Exporters don't pay VAT, importers do.

yread 6y ago
I admit I only looked into very quickly but it seems that UK business might need fiscal representatives in each EU country they do business with https://www.avalara.com/vatlive/en/vat-services/fiscal-representative-for-eu-vat.html https://www.avalara.com/vatlive/en/vat-services/fiscal-repre...

krona 6y ago

I was under the impression that most of the rule changes apply to the vast majority of cross-border B2C sellers in the EU from July: https://www.pwc.ch/en/insights/tax/new-ecommerce-eu-vat-rules-july-2021.html https://www.pwc.ch/en/insights/tax/new-ecommerce-eu-vat-rule...

corty 6y ago

The EU cannot make it any easier. Not because it wouldn't be possible at all, just that it would be suicidal for the EU or its politicians for several reasons. There are tendencies in several members to leave the EU or at least get rid of a few of the treaties. That means that leaving the EU in any really beneficial way for the UK would be strengthening the "leave" position in other members. And while the UK alone leaving is bad, more members leaving would be far worse. Then there is the topic of the UK rebate and the UK's special role in several treaties. The EU has always had to pamper the UK and the UK gave nothing but grief in return. It would have been political suicide for the EU leadership to give any impression of continuing to pamper the Brits in the Brexit treaties. Also, beneficial status for a non-member would weaken the EU position in treaties with other non-members such as Norway, Switzerland, Japan, Canada, etc. And then there is the problem of the UK being not really one country but a haphazard agglomeration of several territories. While Great Britain is somewhat uniform, Northern Ireland is special. There are several reasons for treating it in a special way in the Brexit treaty, like a looming civil war, a possible Irish veto, a possible smuggling route into the EU market. But it was clear from the start that this would hugely complicate matters. Same for Gibraltar and the channel Islands, French and Spanish vetoes looming, etc. I won't be surprised if the Brexit treaties don't hold forever. If the UK feels the squeeze of non-forthcoming trade with the rest of the world and diminishing trade with the EU, a more aligned status like the Norway/Switzerland model is possible. And I guess there will be a realignment of Northern Ireland and Gibraltar in some way, either towards a more unified UK or towards a weakened UK and Spanish/Irish unity, depending on what kind of hit the respective nations will take during COVID and the next few years. But from an internal EU point of view, the current Brexit treaty is the farthest the EU could have gone.

rich_sasha 6y ago
I suspect under the current model, Northern Ireland, and perhaps also Scotland, are untenable as parts of the Union. Northern Ireland is a political chimera that only existed in peace because you could pretend there is one Ireland under EU membership. I think as soon as Brexit pinches for good, NI and Scotland, both of which voted to remain in the EU, are out. Let’s just hope there isn’t another civil war in it.
- joshuaissac 6y ago
  Scotland has far greater trade with the rest of Great Britain than with the EU, so it would be in their interests to remain in the British internal market and customs territory even if they gain political independence.[1][2] Northern Ireland remains in the EU Single Market, so the previous pretense of a unified Ireland within the EU can continue.[3] 1. https://www.ft.com/content/bbf2a097-37ff-42ea-8b22-c5662f0ae4be https://www.ft.com/content/bbf2a097-37ff-42ea-8b22-c5662f0ae... 2. https://www.gov.scot/publications/export-stats-scotland-2018/ https://www.gov.scot/publications/export-stats-scotland-2018... 3. https://www.bbc.com/news/uk-northern-ireland-55427004 https://www.bbc.com/news/uk-northern-ireland-55427004
  - rich_sasha 6y ago
    Brexit was an emotional issue, and I think this would be the same. 68% of Scots voted against Brexit, but the London government ignored that and piled ahead with fairly hard Brexit. Even the fishing industry, the prized jewel in the crown, got pretty screwed by Brexit. I don’t think the Irish arrangement is workable in practice. It’s trying to fit a square peg in a keg of dynamite. The Irish Protocol effectively puts it outside the British economic zone, since trade with Britain is effectively import and export, going thru customs and enormous red tape. Meanwhile, Ireland proper is just across the field. I think Northern Ireland will make it to its centenary but not much beyond.
  - kergonath 6y ago
    > Scotland has far greater trade with the rest of Great Britain than with the EU, so it would be in their interests to remain in the British internal market and customs territory The UK has far greater trade with the rest of the EU than with the rest of the world, so it would be in their interest to remain in the Single Market and Custom Union. I've always found it quite funny when English make this argument about Scotland. Particularly as the last independence referendum was won by the unionist side with a razor-thin margin, under the premises that the way for Scotland to stay in the EU was to stay in the UK. How is it that English nationalists are allowed to be unreasonable, but Scottish should not?

kergonath 6y ago

> The VAT rules alone make it really difficult for small business to export to EU But how would you do otherwise if one of the parties does not want any regulatory alignment and is barely cooperative? There was an easy way of solving this, which the British chose to ignore because they were not Norway.

belltaco 6y ago

UK had a big hand in crafting trade rules with third party countries while in the EU. They then refused the Switzerland arrangement, the Norway arrangement etc. and wanted to become a third party country. And now surprise pikachu face at the consequences of that.