Confused, bemused, past caring? What the fuss is all about: what might the eventual Brexit look like? We compare the latest 'deal' with how other countries have structured their relationship with the European Union. 

  The Boris deal v.1 appears to be similar to Mrs May's deal, key changes appear to be:

  • Changes to the Northern Ireland backstop: these appear to result in a hard border in the sea between UK and N.Ireland.
  • Transfer of certain items from the Withdrawal Agreement to the Political Declaration: this is the area where some MP's require further debate and scrutiny.

Deal options

 

Votes on EU law

Tariff free trade

European Economic Area

Customs Union and external trade

‘Ever closer Union’

Justice and home affairs (JHA)

Free movement of people

Schengen Agreement

Contributes to EU

Euro

UK before Brexit

Y

Y

Y

Y

N

(i)

Y

N

£11b p.a. (a)

N

The Boris deal v.1 N (g)  N N (d) N N + (e) N £39b + (b) N

EU members

Y

Y

Y+(l)

Y

Y

Y (i)

Y

Y (j)+(k)

Y (variable)

Y

Norway

N

(f)

Y

N

N

(c)

Y

Y

Eur 882m (c1)

N

Switzerland

N

(c)

N

N

N

(c)

Y

Y

(c)

N

Canada

N

(c)

N

N

N

N

N

N

N

N

Turkey

N

(c)

N

(c)

N + (h)

N

(c)

N

N

N

Hard Brexit - WTO rules 

N

N

N

N

N

N

N

N

£39b (one-off)

N

 

(a) ONS estimate for 2018 after the UK’s rebate and EU grants (Net).

(b) £36b divorce bill + £15b (average estimate of extra government costs*).

(c) Special and specific arrangements with each country.

(c1) Various individual contribution agreements total, according to Norwegian government.

(d) There is an exception for N. Ireland. Single market rules will be enforced on the Irish Sea.

(e) The exception will be for EU citizens already living in the UK.

(f) Norway is a member of the European Economic Area (EEA). Norwegian goods, except for agriculture and fisheries, are tariff-free into the EU. 

(g) Will ultimately be dependent upon the final agreement between the EU and Britain to be negotiated between now and 2024.

(h) This would change should EU members agree for Turkish membership.

(i) The UK, Ireland and Denmark have special agreements on the JHA, being able to opt out on certain terms.

(j) The UK, Ireland and Cyprus are not part of Schengen. Nor are Bulgaria, Romania or Croatia but they must join in the future.

(k) Leichtenstein and Iceland belong to the Schengen area in spite of not being EU members.

(l) The EEA comprises all 28 EU members plus Norway, Leichtenstein and Iceland.

 

 *Average estimate of extra government costs: this is difficult. Treaties require negotiation, the detail with the EU and measures in implimenting a new policy will take at least 7 years. There will be multiple changes to laws, for example, for tax that would be VAT and excise laws are going to be time consuming. New systems and processes will need to be devised and presumably a new ministry will be in charge of 'brexitisation'. We have simply averaged estimates from a broad range of different leave/remain and neutral sources.

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