The United Kingdom Internal Market Bill (IMB) currently
before Parliament is quite a deceptively named piece of legislation
as it in fact admits the fact of four internal markets within the
United Kingdom.
This is in part a consequence of the Northern Ireland Protocol
in the Withdrawal Agreement, certainly, but it is also a necessary
regulatory mechanism now that the United Kingdom is no longer
within the European Union and more specifically the EU Internal
Market.
The Bill recognises the fact that there are now four devolved
nations and four potentially differing jurisdictions within the
United Kingdom , namely Scotland, Wales, England and Northern
Ireland. Whilst presently more or less integrated it is clear that
regional differences will give rise to differing standards of
regulation in each one. The Bill is intended to provide a
regulatory framework for that economic future .
That therefore excludes from the UK Internal Market the
Crown Dependencies of the Isle of Man, which is a separate economy
with a VAT system integrated into that of the United Kingdom, and
those of the Bailiwicks of Jersey and of Guernsey, who have only
recently introduced systems of a VAT like tax the GST. There are
historicy excise and customs boundaries between these that were
effectively rendered irrelevant durin he application of Protocol
III. They will no longer be irrelevant after 11.00 pm 31st
December, 2020 and trade between the British Islands wil be
affecred
However all of those systems have an area implicit in them,
currently there are no customs or excise boundaries between them,
but that will change in relation to Northern Ireland - UK(NI), and
it is clear that whilst the regulations as to transactions in goods
with the United Kingdom are likely to remain similar in the
immediate, these risk changes as to trading with the four economies
within the UK Internal Market as these start to evolve and
potentially devolve.
It will be interesting to see what might happen to Berwick on
Tweed, which is in a limbo between Scotland and England. Will there
be a potential for an excise free zone in the railway station? I
doubt it.
Services and rights of establishment and professional
qualifications are also addressed in the IMB
Please see a short summary on the
Resources page.