Home / Insight / Brexit


How our law firm can help your business

Back to Brexit
exclamation alerte 220x220

BREXIT : what will happen after 31 January 2020?

On Wednesday January 29th, 2020, the European Parliament approves UK agreement.

Reminder of the Brexit agreement consequences

Following the approval by the British Parliament of agreement 2019/C 384 I/01 published in the OJEU of 12 November 2019 conditions for the exit of the United Kingdom from the European Union (EU) on 31 January 2020 are about to be met.

The completion of ratification procedures is pending and in the very words of Michel Barnier, chief negotiator for the Brexit, “it is now clear that the UK will leave the EU at the end of this month”. The agreement will be implemented, subject to the formalisation of the last ratifying acts before 31 January.

From 1 February 2020, the United Kingdom will no longer be a member of the EU.

Save for some exceptions, the United Kingdom will no longer participate in the EU institutions.

However, the agreement provides that this date will mark the beginning of a transitional period, during which the whole of EU law will continue to apply (with the exception of certain institutional provisions) to the United Kingdom (art. 126 and 127), which will be treated in principle as a member State for the application of the provision of EU law (art. 7 paragraph 1 and 127 paragraph 7).

This implies that EU law will have the same legal effects on the United Kingdom and its territory as within the EU and its Member States.

Likewise, this means, for example, that for the application of a directive which governs operations in a different way according to whether they are carried out with a partner established in a Member State of the EU or with a partner established outside of the EU, a British partner will be treated as being established in a Member State of the EU until the expiry of the transitional period.

The United Kingdom will in principle be required to apply EU law during this period, even if it is amended or replaced and will bear, as all Member States, all consequences of any breach of EU law. This specifically concerns the four EU freedoms (free movement of goods, capital, services and persons).

The transitional period expires in principle on 31 December 2020. However, the agreement provides that it may be extended by a maximum period of one to two years (art. 132).

This period shall be used to organise the relations of the United Kingdom with the EU and/or the Member States from the day following the expiry of the transitional period.

The agreement however already establishes rules in certain areas of law which will apply until up to five years after the end of the transitional period (citizenship, customs, VAT, intellectual property, judicial and administrative cooperation…).

We will shortly present the key elements in each discipline of these specific provisions of the agreement in order to allow you to anticipate the decisions to be made in view of the end of the application of EU law in the United Kingdom.

Finally, the agreement includes three protocols including specific provisions regarding relations with Ireland, Cyprus and Gibraltar.



With the Brexit deadline looming, are you aware of all the consequences related to the United Kingdom withdrawing from the European Union?

It is now more likely than ever that the UK will leave the EU without an agreement in place to govern the new relationship. We would like to remind you of the most relevant legal, financial, tax and employment consequences of a so called “hard Brexit”.

Thanks to a multidisciplinary, tailored offer, our teams can support your adjustment to a hard Brexit and help you manage the challenges you face vis-à-vis the United Kingdom, against a changing and unstable backdrop.

Bouton contact anglais violet foncé 330x110

Hard Brexit: our support offer

Anticiper votre stratégie commerciale - brexit

Ensure your business strategy

Adapter votre fiscalité - brexit

Adapt your tax strategy

Vous accompagner dans votre politique RH - brexit

Support you in your HR policy

Repenser vos enjeux juridiques - brexit

Rethink you legal issues


Show only
VAT re­fund for tax­able per­sons in an­oth­er EU mem­ber state
Dis­cov­er our law firm­'s ana­lys­is of the Court of Justice of the European Uni­on's judg­ment in the Sea Chefs Cruise case.
27 July 2020
Pro­tec­tion for Designs in UK post Brexit
Since 2002, UK busi­nesses have been able to pro­tect their designs by vir­tue of both UK and EU design rights, con­fer­ring par­al­lel but slightly dif­fer­ing forms of pro­tec­tion. This art­icle con­siders the...
Leg­al 500 Par­is 2018
Our firm is one of the best law firms in Par­is. We were ranked in 16 cat­egor­ies of the Leg­al 500 Par­is guide. Tax law, cap­it­al mar­kets... See all our 2018 rank­ings!
04 March 2020
SCIP Data­base: a step for­ward for the cir­cu­lar eco­nomy
From 5 Janu­ary 2021, busi­nesses that sup­ply art­icles or com­plex ob­jects (products) con­tain­ing cer­tain haz­ard­ous sub­stances will have to sub­mit in­form­a­tion to a new data­base es­tab­lished by the European...
28 February 2020
UK/EU fin­an­cial ser­vices after Brexit -cross bor­der reg­u­la­tion after the...
On 25 Feb­ru­ary, the Coun­cil of the EU pub­lished the fi­nal ver­sion of its ne­go­ti­at­ing man­date and, two days later, the UK gov­ern­ment set out its ap­proach to our fu­ture re­la­tion­ship with the EU. Ne­go­ti­ations...
15 November 2019
Brexit and data pro­tec­tion: what to do next (when you don’t know what’s...
Whilst the threat of a no-deal Brexit has been aver­ted for now, the fu­ture is by no means cer­tain. We have high­lighted some of the key is­sues for UK-based or­gan­isa­tions, and the EEA or­gan­isa­tions that...
27 September 2019
Fin­an­cial as­sist­ance to Mem­ber States and European un­der­tak­ings in the...
Brexit without an agree­ment would have im­port­ant con­sequences for the eco­nomy, the la­bour mar­ket and pub­lic fin­ances in the Mem­ber States that have par­tic­u­larly close trade and fin­an­cial re­la­tions with...
26 March 2019
Brexit: what about UK cit­izens work­ing in France?
If no agree­ment is reached between the UK and the EU mem­ber coun­tries, Brit­ish na­tion­als will no longer be EU cit­izens as of  April 12 or May 22, 2019. What will hap­pen to Brit­ish na­tion­als who would...
19 March 2019
Latest news in French tax­a­tion: when the go­ing gets tough, will the tough...
As France faces its very own Winter of dis­con­tent, the Fin­ance Act for 2019 as­pires to re­con­cile com­pet­it­ive­ness and fight against tax avoid­ance. Yet, this two­fold am­bi­tion is clearly not a walk in the...
19 November 2018
France on the verge of passing new meas­ures on go-back bo­nuses for ma­ter­i­al...
With Brexit draw­ing closer, the PACTE bill cur­rently dis­cussed by the French Par­lia­ment con­tains sev­er­al meas­ures aim­ing at as­sert­ing Par­is’ strength as a fin­an­cial cen­ter of the EU. Among those pro­vi­sions,...
10 September 2018
Brexit and the in­sur­ance sec­tor – in­form cus­tom­ers about Brexit’s im­pact...
The European In­sur­ance and Oc­cu­pa­tion­al Pen­sions Au­thor­ity (“EIOPA”) provided an opin­ion on in­form­ing cus­tom­ers about the im­pact of the with­draw­al of the United King­dom from the European Uni­on (“Opin­ion”)....
24 August 2018
Gov­ern­ment Is­sues Brexit Tech­nic­al No­tice for Life Sci­ences
On 23 Au­gust 2018, the UK Gov­ern­ment (the "Gov­ern­ment") is­sued the first wave of its tech­nic­al pa­pers de­signed to provide guid­ance to com­pan­ies to help pre­pare for a "No Deal" Brexit. In this scen­ario,...