Brexit – The consequences

Consequences of a Brexit

Commentators tend to talk about the consequences of a UK exit from the EU as if there is only one route to go if that happens.

If that were the case at least the situation would be clearer and deciding what to do if you live, work or own property in the rest of the EU would be easier.

Three options are generally considered for a post-Brexit UK:

  1. membership of the European Economic Area (EEA)
  2. bi-lateral agreements with the EU covering various subjects
  3. trading with the EU by way of the World Trade Organisation rules

The main areas of concern

The commentators also seem to have very poorly researched what the potential consequences are. Whilst some of what they say about loss of rights and benefits is relevant there is also a good deal that is misleading and seems intended to increase the Fear, Uncertainty & Doubt surrounding the subject instead of passing on fact based information.

First of all it is necessary to clarify the current entitlements/benefits and where they derive from.

The topics below are those that are often mentioned in questions or highlighted in articles

Exchange controls

UK abolished exchange control measures in 1979.

Health Care

Reciprocal health care arrangements under the EHIC apply to EEA & EU countries. The S1 forms are no longer issued to “early retirees” (a UK government decision).

There are reciprocal health care arrangements with a number of non EEA/EU countries ranging from Anguila to Uzbekistan, including Australia, New Zealand & Russia. Whilst this doesn’t prove that there would be reciprocal arrangments if te UK left the EU, it does show that reciprocal arrangments are not just due to EEA or EU membership.

There is no automatic universal access to health care due to EU membership. The arrangements vary from country to country

In France, for instance, to use the system you have to pay into the system if you are a resident and under retirement age. Over retirement age there are no social charges on the UK state pension (the French do not levy social charges on any income derived from having paid social charges). Private pensions are a different matter and are subject to both tax and social charges.

Jobs & Qualifications

There is no universal equivalency of qualifications due to EU membership.

There are only 7 professions which have automatic recognition across the EU. These are the “sectorial” professions:

  • Architects
  • Dentists
  • Doctors
  • Midwives
  • Nurses
  • Pharmacists
  • Veterinary Surgeons

With other professions where there are equivalences based on experience and training, official translations and attestations to course content may be required. Even then it may be necessary to undertake a training period or formal assessment/examination.

Naturalisation

The requirements and procedures for naturalisation are broadly similar in all EU countries:

  • a minimum period of residence
  • language competency
  • cultural integration
  • knowledge and appreciation of the country’s history

However there are considerable variations in the minimum period of residency (3-10 years), language competency (informal interview, formal examination, age related dispensations), need to give up other nationalities

Pensions

Pensions increases are payable to pensioners in almost all European countries and aren’t derived from EU agreements. Some commentators/journals claim that moving outside the EU would automatically result in frozen pensions such as apply to UK pensioners in Australia or Canada.There are a number of countries outside the EU where UK pensioners are treated on the same basis us UK resident pensioners.

Political Rights

EU citizens can to vote in the local & EU elections in the country/area where they live. Of course, if the Conservative party are re-elected in 2015 and they live up to their September 2014 pledge all expatriates will have the right to vote in the UK.

In France an EU citizen can be a local councillor but a mayor or a deputy mayor must be a French citizen.

Residency and/or working

The residency rules we benefit from at the moment derive not only from the EU but would also apply under the EEA arrangements.

Not to be forgotten that even under EU rules there is a difference between a stay of three months or less and a longer one.

“Right of residence for more than three months

The right of residence for more than three months remains subject to certain conditions. Applicants must:

  • either be engaged in economic activity (on an employed or self-employed basis);
  • or have sufficient resources and sickness insurance to ensure that they do not become a burden on the social services of the host Member State during their stay. The Member States may not specify a minimum amount which they deem sufficient, but they must take account of personal circumstances;
  • or be following vocational training as a student and have sufficient resources and sickness insurance to ensure that they do not become a burden on the social services of the host Member State during their stay;
  • or be a family member of a Union citizen who falls into one of the above categories.

Residence permits are abolished for Union citizens. However, Member States may require them to register with the competent authorities within a period of not less than three months as from the date of arrival. Proof of registration will be issued immediately on presentation of:

  • an identity card or valid passport;
  • proof that the above conditions are complied with (see Article 9 of the Directive on the proof required for each category of citizen). Union citizens engaged in training must show, by means of a statement or any other means, that they have sufficient resources for themselves and for the members of their families to ensure that they do not become a burden on the social services of the host Member State. This will be sufficient to prove that they comply with the resources condition.”

In France carte de sejour & work permits do not have language competency requirements

Taxation

Personal taxation arrangements derive from bi-lateral treaties that the UK has with each country. These treaties vary considerably in their scope.

Visas

Where in Europe, Western or Eastern, inside or outside the EU do you need a visa? In general countries do not impose visa restrictions on citizens of developed countries. However if the UK were to impose visa restrictions on people travelling from EU countries then the EU may require visas for UK citizens travelling to the EU. It is true that there may be more thorough checks at the border for UK citizens. But even pre-Common Market, border controls between the UK and the continent were not very time consuming.

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