London is at a crossroads: what kind of execution model Brexit will choose UK

London is at a crossroads: what kind of execution model Brexit will choose UK

A course on acceleration

The UK Supreme court on Tuesday, January 24, rejected the government’s appeal, affirming the decision of a lower court (the High court of London) that the Parliament must vote to start negotiations for the country’s exit from the European Union.

A lawsuit in London’s High court the government filed the financier Gina Miller and Barber Deira DOS Santos. The government in the appeal, insisted on their right to begin the process Brexit without the sanction of Parliament on the basis of the so-called Royal prerogative (she previously gave to the monarch, and now the government in exceptional cases to act without the approval of Parliament), and also referred to the law on referendum on leaving the European Union. He, according to the government, was responsible for the implementation of the results to the Cabinet.

However, the Supreme court disagreed with this interpretation. Now the Prime Minister Theresa may will have to wait for discussion and vote in Parliament to start negotiations with Brussels. As noted by the newspaper The Washington Post, in case you lose in court, the government will try as soon as possible to submit to the deputies a plan of negotiations to try to pass all the approval stages and to start a dialogue with Brussels no later than the March 31 deadline fixed by may. The government intends to submit its bill in the coming days, said on 23 January the British newspaper the Independent, citing government sources.

After the verdict of the Supreme court, the press service of the government stressed that the failure of the appeal will not change the plans may: the Cabinet of Ministers intends in coming days to make public its further tactics until the end of March to begin the process of negotiations. According to The Washington Post, the refusal of Parliament from Brexit unlikely: the electorate MPs will consider such a move is undemocratic, the Parliament may face a crisis of confidence.

The third way

The government’s vision for the future of the process may announced last week, speaking at the British foreign office. From the speech of the Prime Minister implies that the government is looking for an intermediate path between maintaining socio-economic ties with the EU (“soft” Brexit) and a complete rejection of integration with the transition to cooperation with the European Union on the common rules of the world trade organization (“hard” or “pure” Brexit). According to The Sunday Times, the intermediate circuit in addition to may be the Minister of EU exit David Davis and Finance Minister Philip Hammond. They oppose foreign trade Minister Liam Fox and foreign Minister, Boris Johnson, convinced of the need for a deep separation with the EU.

In the case of election of the interim approach the basic principle of trade-economic relations of great Britain with the EU will be reduced to the output of the pan-European agreements and replacing them with bilateral agreements Kingdom with the EU on specific issues, writes The Guardian. Instead of the Common market, which requires the transfer of EU sovereignty in immigration and judicial Affairs, Mae stands for “maximally wide” free trade agreement. Instead of the Customs Union (TSES), which ties the hands when trading with third countries, may offers customs agreement on free trade, at least in some sectors.


If London is to voluntarily participate in any pan-European programmes UK government is ready to pay the target fees, but after not going to pay billions of dollars in payments to the EU budget.

In the area of migration, may announced its intention to restore sovereign control over borders to control the flows entering. But it promised to support the rights and freedoms of expats (working in the continent of the British and working in the UK EU citizens). She also confirmed the intention to maintain freedom of movement with neighbouring Ireland. More detailed migration program, the government yet.

The Prime Minister supported the idea of transition, the duration of which is not yet defined. Supporters of the “hard-line” require immediate withdrawal from the EU after agreements, and businessmen in favor of a phased withdrawal from EU integration to reduce economic damage.

The speech may have cheered opponents of the European Union. Boris Johnson called it a “fantastic speech” which “explains all how to leave the EU, remaining in Europe.” The former head of the independence Party and one of the leaders of the movement for Brexit Farage contentedly noticed that the Prime Minister “uses now the same words and expressions for which I spent years making fun of”.

Examples for Britain

In addition, in his speech, may said: “Britain is not trying to adapt the existing model of relations with the European Union, which are available in some countries” (quote via The Guardian). However, since the referendum on leaving the EU in late June and policy experts liken the procedure to a possible Brexit from the already known ways of building relations with the EU. Based on the speech of the Prime Minister, London focuses on using items from different models.

If Britain remains in the European economic area (EEA), it will join Norway, Iceland and Liechtenstein. They also come in a free trade Area (EFTA). These countries have virtually all the rights and obligations of EU membership. The EFTA countries are not included in the Customs Union that allows them to conduct independent trade with third countries. They are also exempt from the annual contributions to the EU budget, while paying its membership in EFTA. Norway spends a €50 million a year. The rest of the EFTA countries are subject to the European rules of free movement of people, money, goods and services. If the UK is to choose the model of the three countries, it can be described as “soft” Brexit.


Relations between Switzerland and the EU more “hard”. Formally, Switzerland is also a member of the EFTA, but in a referendum in December 1992, the citizens of the Confederation voted against the automatic entry into the EEA. Instead of a single comprehensive agreement, Switzerland has partial access to the EU Common market through a number of bilateral agreements with Brussels. Turkey participates only in the Customs Union. For Turkey within the Union a duty-free regime applies to all sectors except agriculture.

As close to “hard” Brexit is the position of Canada. The country does not have any special relationship with the European Union, with the exception of an extensive free trade agreement, signed in October 2016, but not yet ratified. The agreement will remove tariffs on goods that make up 99% of trade between Canada and the EU.

In late September, the sources bi-Bi-si the British government announced that preferred the London model Brexit is a model of “Canada plus”, which would include a free trade agreement, the removal of most duties and the conclusion of separate agreements on the facilitation of cooperation in various sectors, such as financial.

Finally, the “hard” Brexit — is a complete rejection of attempts to save the elements of integration and the transition to economic and trade relations with the EU on the basis of WTO rules. Duty on all the goods in this case will be not less than 5%. According to the latest British statistical offices ONS, the merchandise imports of the UK from the EU amounted in November 2016 £21,95 billion ($28 billion). Accordingly, the loss of the British from imposing tariffs can reach up to £1.1 billion ($1.4 billion).


Despite all the costs and whether government has the “technical ability” to review the decision on withdrawal from the EU, it is highly unlikely that it would use it, said during the discussion at the Gaidar forum in Moscow, the Financial Times columnist Martin wolf.

With the participation of Natalia Demchenko