The Brexit Boiler Room - The key challenges in the tax landscape - Salas Piantini
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The Brexit Boiler Room
The key challenges in the tax landscape
8 - 12 September 2019 | London, England www.ifa2019london.com | IFA©2019
The Brexit countdown
DAYS HOURS MINS
www.ifa2019london.com | IFA©2019 2
Speakers
Melissa Geiger Sandy Bhogal Amanda Tickel Andrea Tolley Neil Sherlock
Chair Panel Members
www.ifa2019london.com | IFA©2019 3
Agenda
01 Introduction, Brexit refresher
02 Direct Tax
03 Indirect tax
04 Business issues
05 Final thoughts
www.ifa2019london.com | IFA©2019 4
Brexit: how did we get here?
Withdrawal Agreement
Referendum Result PM Steps Down
Then PM David The UK and the EU negotiate
Article 50 New UK PM
Cameron comments 51.9% vote to leave the text of the draft Withdrawal PM May steps down
he is in favour of an the EU and PM PM May triggers Agreement which is defeated in as Conservative Party EU Review of Boris Johnson
in/out EU referendum Cameron resigns Article 50 UK Parliament leader Brexit progress becomes PM
23 Jan 2013 23 Jun 2016 29 Mar 2017 Jun 2017 - Jan 2019 7 Jun 2019 30 Jun 2019 24 Jul 2019
7 May 2015 13 Jul 2016 8 Jun 2017 29 Mar 2019 20-21 Jun 2019 2 Jul 2019
UK General Election New UK PM UK General Election Article 50 Deadline European New European
Council summit Parliament
PM Cameron wins Theresa May PM May loses her The 2 year deadline
general election with becomes PM majority and enters into passes following the Finland assumes the
a manifesto that includes an agreement with the trigger of Article 50 Presidency of the
in/out EU referendum DUP to retain power Council of the EU
www.ifa2019london.com | IFA©2019 5
Brexit: what happens next?
UK Parliament New European Deadline to agree a deal or a
in recess Commission appointed further Article 50 extension
and confirmed must be requested
Mid July – Mid October 2019 19 October 2019
Early September 2019
9 Sept-13 Oct 2019 17-18 October 2019 31 October 2019
UK Parliament prorogued European End of
Council summit Article 50 extension
During this period there is little ability
for any new UK PM to renegotiate or
progress anything with the EU27
www.ifa2019london.com | IFA©2019 6
www.ifa2019london.com | IFA©2019 7
Brexit scenarios
Ahead of the current cliff-edge date of 31 October, five key Brexit scenarios currently remain in play:
1. Renegotiated deal What it is: UK and EU agree a deal that is ratified by 31 October. UK then enters transition period
2. ‘Managed’ no deal What it is: UK leaves EU on 31 October without a deal. “Limited” measures to mitigate impact
3a) Further extension –
What it is: EU agrees to extend talks beyond 31 October to explore renegotiation of existing deal
for continued talks
3b) Further extension – What it is: EU agrees to an extension beyond 31 October for UK government to hold a second referendum in
for second referendum order to seek a mandate for their Brexit plan
3c) Further extension – What it is: EU agrees to an extension beyond 31 October so that new can PM triggers election – or is forced in
for General Election to one – prior to the UK leaving the EU
www.ifa2019london.com | IFA©2019 8
The Brexit log jam
EU-27
Future trading
relationship
with EU
Member
States Impact on
the customs
Financial union and
services the Single
regulation Market
The Irish
backstop The Free
The future The UK’s Movement
of the obligation of People
Withdrawal EU FTA States to pay the
UK’s position in Brexit The contents
Agreement
relation to states ‘divorce bill’. of the Political
WTO
which have FTAs declaration
relationship
with EU (e.g. with RoW
South Korea) Status of
UK in WTO
www.ifa2019london.com | IFA©2019 9
The Brexit log jam
EU-27
Future trading
relationship
with EU
Member
States Impact on
the customs
Financial union and
services the Single
regulation Market
The Irish
backstop The Free
The future The UK’s Movement
of the obligation of People
Withdrawal EU FTA States to pay the
UK’s position in Brexit The contents
Agreement
relation to states ‘divorce bill’. of the Political
WTO
which have FTAs declaration
relationship
with EU (e.g. with RoW
South Korea) Status of
UK in WTO
www.ifa2019london.com | IFA©2019 10Legal and political
considerations – direct tax
www.ifa2019london.com | IFA©2019 11EU law considerations
The European Communities Act 1972 provides for the supremacy of EU law.
Accordingly, it will need to be repealed or amended for Brexit to take effect and
to end the constitutional relationship between the EU and the United Kingdom.
Provisions in the EU treaties, including the “four freedoms” (free movement of
goods, services, capital, and persons), and EU regulations have direct effect in the
member states without the need for separate domestic legislation. In contrast, EU
directives must be implemented by member states, thereby requiring domestic
legislation.
The principle of direct effect has been established by the European Court of
Justice to give effectiveness to EU law. It means that a piece of EU law may
be capable of having direct effect if it is sufficiently clear and precise and
unconditional and needs no additional implementing measures. On the Brexit
date, EU law will cease to have direct effect in the UK.
www.ifa2019london.com | IFA©2019 12EU law considerations
The European Union
(Withdrawal) Act The repeal of the European Communities Act 1972, with effect from the
2018 became law by Brexit date
royal assent on June
26. It provides for:
The preservation of retained EU law as it stands on the Brexit date
The inclusion of delegated powers enabling the U.K government to amend
primary and secondary legislation to address deficiencies in the preserved EU law
and thus enable those laws to operate as intended. These powers alone, however,
are not sufficient to create or legislate any new policy
www.ifa2019london.com | IFA©2019 13Direct tax challenges
1 Practical implications of Brexit for direct taxes
2 EU directives ceasing to have direct effect
3 ECJ jurisprudence
4 Limitation of Benefit issues
5 Inward and outward investment
www.ifa2019london.com | IFA©2019 14Direct tax challenges
Practical implications of Brexit on Direct Taxes
The deadline of the withdrawal of the UK from the EU according to Primary EU law - EU fundamental freedoms laid down in the EU Treaty will no
Article 50 of the Treaty on the European Union is set to expire on 31 longer apply in relation to cross-border economic activities between the UK and
October 2019 (subject to potential extension). the other EU member states
In the absence of a deal, after such date, there will be significant Secondary EU law - non-application of the EU Directives and cessation of direct
consequences for the direct tax treatment of cross-border activities effect. Note that Annex 4 of the Withdrawal Agreement lays down a commitment
between the UK and the member states of the EU. from the UK to continue to apply the provisions of its domestic law that
transpose certain Directives such as the ATAD and the DAC – this will only apply
if a deal is agreed and the Withdrawal Agreement is ratified.
www.ifa2019london.com | IFA©2019 15Direct tax challenges
EU Directives ceasing to have direct effect
In terms of secondary EU law, the UK withdrawal will mean the non application of EU directives and
cessation of direct effect. This will apply in particular to:
● Parent Subsidiary Directive (Council Directive 2011/96/EU of 30 November 2011);
● Interest and Royalty Directive (Directive 2003/49/EC of 3 June 2003);
● Merger Directive (Council Directive 2009/133/EC of 19 October 2009);
● Directive on Administrative Cooperation (DAC) (Council Directive 2011/16/EU of 15 February 2011);
● Anti Tax Avoidance Directive (ATAD) (Council Directive (EU) 2016/1164 of 12 July 2016); and ATAD II
● Directive on tax dispute resolution mechanisms in the European Union (Council Directive (EU
2017/1852 of 10 October 2017).
www.ifa2019london.com | IFA©2019 16Direct tax challenges
EU Directives ceasing to have direct effect
Access to EU Directives has been part of the standard toolkit for EU cross-border tax planning and any
form of Brexit would affect this.
Example:
● For incoming dividends (i.e. dividends received by a UK holding company from EU countries), in a lot
of cases the local implementation of the EU Parent/Subsidiary Directive was used to reduce the
dividend withholding tax in the distributing country to zero. After Brexit, companies may no longer
have access to this favourable EU system and would hence fall back to the concluded tax treaty with
the UK.
● Accordingly, organisations will need to consider how this may impact repatriation of their profits and
the extent to which tax treaties can ameliorate the issue.
www.ifa2019london.com | IFA©2019 17ECJ Jurisprudence
After Brexit, the ECJ will lose its Over the years, the Court of
competence in relation to the UK, Justice EU ("ECJ") has issued
so claims to the direct application of various decisions on cross border
ECJ case law would no longer apply. direct tax elements.
This includes, for example, case law on the importation
of certain tax losses, the access of permanent
establishments to tax treaties with third countries and
the legal recognition of foreign entities.
www.ifa2019london.com | IFA©2019 18Limitation of benefit issues
www.ifa2019london.com | IFA©2019 19Inward and outward investment
As a result of Brexit, there could also be considerable collateral damage vis a vis UK’s trading relationships
Examples
Corporate law: The UK Companies (Cross-Border Mergers) Regulations
2007 (“CBM Regulations”) implement the provisions of EU Directive
2017/1132/EU which provides a mechanism for UK companies to merge
with companies registered in other European Economic Area states.
As a result of the Companies, Limited Liability Partnerships and Partners
hips (Amendment etc.) (EU Exit) Regulations 2019, the CBM Regulations
and associated legislation will cease to apply on “exit day”.
The government published guidance which states: UK companies using
the EU Cross Border Merger regime should be at an advanced stage of
the process if they are to complete mergers before Brexit. These
mergers must be completed by exit day.
www.ifa2019london.com | IFA©2019 20Inward and outward investment
Examples
More stringent rules will apply to benefit from German participation
exemption on receipt of dividends from a UK investee company once
the UK company is not an EU resident (15% rather than 10%).
Horizontal tax groups: Several member states amended their tax group
regimes allowing resident subsidiaries whose shares are held directly
by the same non-resident parent company to form a fiscal unity (see
SCA Group Holding (Case C-39/13 to Case C-41/13)). Such horizontal
tax group regimes introduced by member states are conditional on the
EU status of the holding company.
After Brexit, sister companies held by the same UK parent may not be
able to form a horizontal tax group.
There may also be an impact on horizontal tax groups already in place
at the time of the withdrawal of the UK from the EU.
www.ifa2019london.com | IFA©2019 21Case study
UK Co
French sub
French sub Italian sub Belgian sub Lux sub
sister co
10%
Tax consolidation 5% div LOB
interest
• All subsidiaries 100% owned by UK HQ Co
• Interest and Royalties Directive: The directive currently provides for zero WHT on interest and royalties where 25% or more of capital
(or voting rights) of subsidiary owned by EU parent co. Post Brexit, the Belgian subsidiary’s interest payment to the (non EU) UK parent co will
attract a treaty rate of 10%.
• Parent-Subsidiary Directive: The directive currently provides for zero WHT on dividends where 10% or more of capital (or voting rights) of sub
sidiary owned by :EU parent co. Post Brexit, the Italian subsidiary’s dividend to (non-EU) UK parent co will attract a treaty rate of 5%.
www.ifa2019london.com | IFA©2019 22Case study
UK Co
French sub
French sub Italian sub Belgian sub Lux sub
sister co
10%
Tax consolidation 5% div LOB
interest
• All subsidiaries 100% owned by UK HQ Co
• Tax consolidation: French subsidiaries held through a subsidiary located in the EU or EEA can be tax consolidated with the other French
companies. On Brexit, if the UK Co is no longer part of the EU and EEA, the French tax consolidated group will be broken.
• Limitation of Benefits: US/Luxembourg treaty provides that benefits may currently be available where 95% of the shares of a Luxembourg
company are ultimately owned by seven or fewer residents of NAFTA/EU countries. Such benefits would be lost if the UK Co is no longer
part of the EU.
www.ifa2019london.com | IFA©2019 23The New Legal Order
1 European Union (Withdrawal) Act 2018
2 Incorporation of pre-Brexit direct EU legislation into UK law
www.ifa2019london.com | IFA©2019 24European Union (Withdrawal) Act 2018
In June 2016, the UK voted to leave the EU in a referendum on EU membership
On 29 March 2017, the Prime Minister gave a letter to the European Council,
formally notifying them of the UK's intention to leave the EU
This triggered Article 50 of the Treaty on European Union which in turn started a
two-year period for the negotiation and conclusion of a UK-EU withdrawal agreement
The UK’s exit from the EU was due to take place on 29 March 2019 but this has been
extended to 31 October 2019
The EU Withdrawal Act 2018 is now in place. This act intends to “copy and paste” EU law into domestic law on
Brexit Day
The EU Withdrawal Act 2018 will repeal the European Communities Act 1972 following Brexit
www.ifa2019london.com | IFA©2019 25Brexit: The New Legal Order
Incorporation of pre-Brexit direct EU legislation into UK law
The intention is for the EU Withdrawal Act 2018 to incorporate pre-Brexit direct EU legislation into UK law on Brexit Day
This is necessary as it is likely that Brexit will impact pre-Brexit transactions. Business transactions or group reorganisations
carried out before Brexit might have benefited from regimes that were subject to EU status
Example
Exit Taxation: Several EU member states grant companies that transfer their tax residence to other member
states (and lose their tax residence in the member state of origin), the option to defer the payment of the
exit tax due upon transfer. (See judgement in National Grid Indus (Case C-371/10) regarding the
compatibility with the freedom of establishment of exit taxation regimes)
Following Brexit, companies that transferred their tax residence to the UK and deferred the payment of the
exit tax in their member state of origin may now be deemed to have transferred residence to a third
country which may trigger an immediate obligation to pay the outstanding amount of the exit tax.
www.ifa2019london.com | IFA©2019 26State Aid
1 Introduction
2 Group financing exemption in UK CFC regime
3 Future of State Aid following Brexit
www.ifa2019london.com | IFA©2019 27State Aid: introduction
The settled case-law of the Court of Justice of the European Union provides that, for a national measure to be
classified as State Aid, the measure must:
1) confer an economic advantage on companies which is not received under normal market conditions;
2) the advantage must be selective;
3) be granted by the State or through State resources; and
4) be liable to distort competition and affect trade between Member States.
The relevant issue for state aid tax cases is primarily in relation to selectivity. The European Commission’s conclusion
that the group financing exemption within the UK's CFC regime constitutes unlawful state aid forms part of the
evolving jurisprudence regarding state aid and selectivity.
www.ifa2019london.com | IFA©2019 28Group financing exemption in the UK CFC regime
3 stage test applied to determine whether the
advantage was selective:
The European Commission has concluded that
the group company exemption in TIOPA 2010 Part
9A constitutes unlawful state aid in certain 1 Appropriate reference system
circumstances whereby the significant people
functions (SPF) criterion is applied.
Group financing exemption as a
The Commission concluded that the exemption 2 derogation from the general CFC regime
allowed UK companies with a CFC earning
non-trading finance profits (NTFP) from loans made
Whether the group financing exemption
to foreign group companies either to eliminate or 3 is justified
reduce the CFC charge.
www.ifa2019london.com | IFA©2019 29State Aid: UK Government response
The European Commission gave the UK two months to identify the beneficiaries of the aid and only four months to
complete full recovery of the aid. Reports are circulating that the UK has missed its 5 August deadline to recover the
state aid from recipients.
HM Treasury has confirmed that on 12 June 2019 the UK Government made an annulment application to the EU General
Court against the European Commission’s decision that the financing company exemption within the UK’s CFC regime
gave rise to State Aid.
The UK’s arguments against the EC’s ruling include
The UK alleges manifest error of assessment on the part of the EC in selecting
the UK's CFC rules as the reference framework for an examination of
comparability. The UK argues that the proper reference system is the UK's
corporate tax framework as a whole
The exemptions contained in Chapter 9 of the TIOPA 2010 are not derogations
as the exemptions from the broad CFC rules used in Chapter 9 are intended to
operate as a filter
www.ifa2019london.com | IFA©2019 30State Aid: UK Government response
The UK’s arguments against
the EC’s ruling include 1 2 3
UK alleges a manifest error of
UK argues that the
assessment regarding selectivity
EC erred in UK has a certain
The UK government argued
concluding that the level of discretion in
that the EC was wrong to find
relevant exemptions exercising their
that the UK should have relied
granted a 'benefit' competence in the
only on a 'significant people
to any company so field of direct
functions' test as opposed to
as to affect intra-EU taxation.
Chapters 5 and 9 of TIOPA 2010
trade.
operating together.
Notwithstanding the application for annulment, the UK Government is obliged
to push ahead with recovery of the State Aid and it is understood that initial
recovery action will be assessed directly by HMRC and not recovered via the
self-assessment system.
www.ifa2019london.com | IFA©2019 31Future of State Aid following Brexit
Whilst the UK is preparing to leave the EU, it is reasonable to assume that EU state aid
rules will form part of any agreement between the UK and the EU on their future
relationship.
As long as the UK is part of the EU, state aid rules have direct effect without the need for
domestic implementing legislation.
The Government published a guidance paper on 23 August 2018 entitled “State aid if
there's no Brexit deal”. Highlights from the guidance are as follows:
1 The government will create a UK-wide subsidy control framework to ensure the
continuing control of anti-competitive subsidies.
2 The EU state aid rules will be transposed into UK domestic legislation under the
European Union (Withdrawal) Act 2018.
3 The Competition and Markets Authority will take on the role of enforcement and
supervision for the whole of the UK.
www.ifa2019london.com | IFA©2019 32Panel discussion
www.ifa2019london.com | IFA©2019 33Polling question #1
Will the UK reduce its corporation tax rate further to
12.5% to simulate the economy?
A Yes
B
B No
C Don’t Know
C www.ifa2019london.com | IFA©2019 34Panel discussion
www.ifa2019london.com | IFA©2019 35Indirect tax
considerations
www.ifa2019london.com | IFA©2019 36Towards a no deal outcome?
Some key WTO agreements:
• General Agreement on Tariffs and Trade
• General Agreement on Trade in Services
• Agreement on Trade-Related Aspects of
Intellectual Property Rights
• Government Procurement Agreement
Source: European Commission, December 2017
www.ifa2019london.com | IFA©2019 37Towards a no deal outcome? Source: https://ec.europa.eu/commission/publications/slide-customs-controls_en www.ifa2019london.com | IFA©2019 38
No deal impacts
Key supply chain impacts of a no deal scenario – customs, tax and trade
Trading on WTO terms with EU;
Ability to make imports and Additional systems, data and
third country Continuity
exports; EORI numbers reporting requirements
Agreements?
Duty amount: origin, valuation
Potential delays at port; UK free to negotiate new FTAs,
and classification; potential
Authorised Economic Operator but timing?
mitigations
EU VAT simplifications no
Additional compliance costs Supply chain change to manage
longer apply in the UK; import
e.g. broker charges disruption; Incoterms used
VAT on UK/EU flows
www.ifa2019london.com | IFA©2019 39Incoterms: defining responsibilities
Responsibilities EXW FCA FAS FOB CFR CIF CPT CIP DAT DAP DDP
Export clearance
1. Supplier vs customer risk
Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller Seller
Transport to port of exit Buyer Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller
Unloading at port Buyer Buyer Seller Seller Seller Seller Seller Seller Seller Seller Seller 2. Contract vs practice
Loading charges Buyer Buyer Buyer Seller Seller Seller Seller Seller Seller Seller Seller
Freight cost to 3. VAT: Incoterms indicative
destination port Buyer Buyer Buyer Buyer Seller Seller Seller Seller Seller Seller Seller
Unloading at destination Buyer Buyer Buyer Buyer Seller Seller Seller Seller Seller Seller Seller 4. Incoterms 2020 expected
Loading to transport Buyer Buyer Buyer Buyer Buyer Buyer Seller Seller Seller Seller Seller to be released shortly
Freight charges to
destination Buyer Buyer Buyer Buyer Buyer Buyer Seller Seller Seller Seller Seller
Insurance Buyer Buyer Buyer Buyer Buyer Seller Buyer Seller Seller Seller Seller
Import clearance Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller
Import duties Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Buyer Seller
www.ifa2019london.com | IFA©2019 40Customs: quantifying the duty payable
Three factors determining the amount of duty payable:
Classification
Valuation
The amount of duty paid is
based on the commodity Elements such as freight Origin
code assigned to the goods and insurance need to be
added to the customs value Some countries may qualify for
of the goods reduced rates of customs duty e.g.
if a free trade agreement is in place.
www.ifa2019london.com | IFA©2019 41Managing customs: reporting
From Intrastat (9 data fields) to Customs
declaration (54 data fields)
www.ifa2019london.com | IFA©2019 42Managing customs
Requirements for Who will submit the Customs regimes
EORI number
customs declaration customs declaration? and procedures
— Auto-enrolment for — Data: does the ERP — Art.15(1) of The Customs — Can additional duty costs
UK VAT registered system hold the (Import Duty) (EU Exit) be mitigated?
businesses necessary data fields Regulations 2018: a
— Is Authorised Economic
and is the data accurate? person must usually be
— EU EORI number Operator (AEO) status be
established in the UK to
requirements — Customs knowledge and neficial for the business?
make customs
experience – in-house
declarations. Similar rules
or outsource?
apply in the EU under
the Union Customs Code
www.ifa2019london.com | IFA©2019 43Continuity Agreements
01 The Andean countries 08 Israel
— The UK is aiming to sign
continuity bilateral trade 02 CAROFORUM trade bloc
agreements with non-EU 09 Liechtenstein
countries so that trade can
continue with minimal 03 Central America
disruption after the UK 10 Pacific states
leaves the EU. 04 Chile
11 Palestinian Authority
— The UK has so far signed Eastern and Southern Africa
05 trade bloc
continuity agreements with1:
12 South Korea
06 Faroe Islands
07 Iceland and Norway 13 Switzerland
1 UK Government, 2019
https://www.gov.uk/guidance/signed-uk-trade-agreements-transitioned-from-the-eu
www.ifa2019london.com | IFA©2019 44Trade beyond tariffs
Some Continuity Agreements more limited Increasing trade in services:
coverage than current EU FTA: — Rise of cross-border trade in services,
— Trade in Services investment and digital trade
— Rules of Origin — International value chains becoming
more knowledge-intensive e.g. intellectual
— Mutual Recognition Agreements
property, brands, software
— Direct links between manufacturing and
services industries
Trade and Tax: Increasing sophistication of technical
barriers to trade:
— US investigation into France’s Digital
Services Tax — Complex product standards
— Is the tax discriminatory or unreasonable — Regulatory overlaps
to an extent that it will harm US — Non-recognition of qualifications
companies?
www.ifa2019london.com | IFA©2019 45VAT considerations
Additional EU27 VAT registrations
Does your business send A number of positive developments for UK businesses:
goods to the EU-27 from
the UK and vice versa? — Import VAT cashflow cost: mitigated by the planned
Does your business supply
electronically-supplied
introduction of deferred import VAT accounting
services from the UK to the
Does your business make EU-27 or vice versa? — Specified Supplies: VAT recovery on supplies of
use of simplifications, such
as supply and installation? many financial services to non-UK counterparties
Do use and enjoyment
provisions come — Tour Operators Margin Scheme (TOMS): The VAT
Does your business make into play?
B2C distance sales from
due on the margin in relation to EU sales will be zero
the UK to the EU-27 and rated – as is the case currently for non-EU supplies –
vice versa? rather than standard rated
www.ifa2019london.com | IFA©2019 46Import VAT recovery: who owns the goods?
HMRC’s Brief 2 2019 sets out HMRC’s position that only the owner of the goods can recover import VAT.
In a no deal Brexit scenario, this will become a more prominent issue for many businesses.
— Incoterms are not determinative of the VAT position
— Contractual provisions: transfer of ownership
— How does this interact with customs arrangements?
www.ifa2019london.com | IFA©2019 47Indirect tax: actions for businesses
01 Identify the Customs and VAT touchpoints within supply chains
02 Assess trade continuity and market access
03 Review Incoterms – are changes needed? Do practical arrangements match the contract?
04 Apply for EORI numbers if necessary – UK auto-enrolment for UK VAT registered businesses but may need EU EORI number
05 Understand requirements for a customs declaration and how you will submit
06 Appoint a customs broker / third party logistics provider if necessary
07 Quantify the potential additional duty and related costs
08 Obtain a Duty Deferment Account and Customs Comprehensive Guarantee / check if limits need to be increased for existing arrangements
09 Apply for VAT registrations if required
10 Check accuracy of master data e.g. for classification, origin, valuation, counterparty location
11 Determine plan for systems changes for post-Brexit scenario
www.ifa2019london.com | IFA©2019 48Panel discussion
www.ifa2019london.com | IFA©2019 49Business issues and the
impacts on taxation
www.ifa2019london.com | IFA©2019 50Brexit: GSK programme
Context and Objective
There are 5 priority areas which particularly affect GSK
01 Manufacturing and supply Brexit Operational Objective
To ensure patients and consumers in the UK and
02 Regulatory EU are able to continue to access the medicines,
vaccines and healthcare products by minimising
cost and disruption to GSK’s business operations
03 Trade and taxation
and supply chain, following the UK’s withdrawal
from the EU.
04 People
05 Research and development
An integrated milestone plan is in place to deliver changes
The continued uncertainty about the future trading relationship between the EU and the UK means that a number of assumptions have been
used to underpin the plan, e.g. in a worst case scenario, WTO rules will apply and no transition agreement will be agreed between the EU and
the UK
www.ifa2019london.com | IFA©2019 51GSK Brexit structure
Structure for GSK Brexit operational planning and advocacy
Brexit CET Steering Consumer
Company stakeholders
Committee (PT) Pharma
Vaccines
Brexit Operational Lead
ViiV
BREXIT OPERATIONS TEAM : delivering the Brexit change
Manufacturing Regulatory Trade & Tech
R&D People
& Supply Framework Taxation
SME
networks
BREXIT ADVOCACY TEAM : shaping the evolving Brexit world
www.ifa2019london.com | IFA©2019 52Panel discussion
Melissa Geiger Sandy Bhogal Amanda Tickel Andrea Tolley Neil Sherlock
Partner, KPMG LLP Partner, Gibson Dunn Global Head of VP, Group Head of Tax (CBE) Ex Special Adviser
Brexit, Deloitte Strategy & Transfer to Nick Clegg; PwC
melissa.geiger sbhogal
Pricing, GSK Plc Senior Adviser &
@kpmg.co.uk @gibsondunn.com ajtickel
Co-Chair French
@deloitte.co.uk andrea.x.tolley
Chamber of Commerce
@gsk.com
Brexit Forum
neilrsherlock63
@gmail.com
www.ifa2019london.com | IFA©2019 53Polling question #2
Deal or NO Deal?
A Yes
B
B No
C Don’t Know
C www.ifa2019london.com | IFA©2019 54The Brexit countdown (revisited)
DAYS HOURS MINS
www.ifa2019london.com | IFA©2019 55Thank you
www.ifa2019london.com | IFA©2019 568 - 12 September 2019 | London, England www.ifa2019london.com | IFA©2019
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