In-House Counsel Masterclass Brexit Legal Tuesday 4 April 2017
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1 In-House Counsel Masterclass Brexit Legal Tuesday 4 April 2017
2 2
3 Welcome Declan Black Managing Partner Mason Hayes & Curran
4 Banking, Lending & Brexit Will Carmody Partner Mason Hayes & Curran
5 Banking, Lending & Brexit Domestic Irish economic impact and effect on banking business Movement of UK based financial services business to Ireland Contractual implications for lending agreements
6 Hard Brexit and Financial Services Regulation Fionán Breathnach Partner & Head of Financial Services Regulation Mason Hayes & Curran
7 Hard Brexit and Financial Services Regulation where are we now? third country equivalence Irish response
8 Equivalence clauses in key EU financial legislation Financial Services EU Legislation Are there equivalence clauses? Do they grant access to the Single Market ( passportlike )? Banking MIFID/MIFIR (investment services and activities) Yes Yes, partially (If equivalence is granted, third-country firms can operate anywhere in the EU to serve professional clients) CRD IV/CRR (wholesale and retail commercial banking) Yes No (equivalence only covers the prudential treatment of exposures to foreign institutions) Asset Management AIFMD (Non-UCITS Funds marketed to professional clients) Yes Yes (possibility of extending the passport of non-eu fund managers based on positive advice from ESMA) UCITS (EU-domiciled funds capable of being marketed to retail clients) No No Insurance Solvency II (insurance and re-insurance activities) Yes Yes, partially (if equivalence granted, passport-like rights for reinsurance companies only) Market infrastructure EMIR (central clearing counterparties CCPs) Yes Yes (if equivalence is granted, passport-like rights for central clearing counterparties-ccp) Payment Services/Emoney PSD/PSD II EMD II No No
9 Employment Law Melanie Crowley Partner & Head of Employment Law and Benefits Mason Hayes & Curran
10 Implications for Employers Immigration free movement of workers Employment law unlikely to be wholesale changes in the short term Pensions implementation of IORP II Cross border pension schemes
11 Tax Consequences of Brexit Niamh Keogh Tax Of Counsel Mason Hayes & Curran
12 Tax- Current environment A time of change Consider group structures and supply chains to assess potential impact of developments, including Brexit. OECD BEPS project EU initiatives eg Anti-Tax Avoidance Directive (ATAD) US tax reform Brexit
13 Tax- UK tax changes Increased flexibility? Fundamental freedoms State aid Loss of beneficial Directives Parent Subsidiary Directive Interest and Royalties Directive Cross- Border Mergers Directive Impact on UK holding company regime Irish alternative
14 Tax- Example UK Parent Interest on loan 100% 100% 100% 100% Royalties Portuguese Subsidiary French Subsidiary Italian Subsidiary Irish Subsidiary Pre-Brexit: Benefit of EU Directives No withholding tax on dividends, royalties or interest Post-Brexit: Rely on domestic exemptions or Double Tax Treaties Withholding tax on dividends from Portugal and Italy Withholding tax on Portuguese 10% Withholding tax on Italian 8%
15 Move EU ops to new EU hub US FinCo UK FinCo Shares New Irish FinCo UK ops EU Transfer
16 Tax- Irish issues Some reliefs available only for EU/EEA counterparties eg stamp duty reconstructions Irish CGT group relief and clawback risk if UK leaves CGT group Potential Irish regime enhancements? Coffey report
17 Tax- other issues VAT Uncertainty, UK flexibility Mini One Stop Shop (MOSS) for B2C electronic services Mutual assistance and information sharing
18 Brexit - Business Unusual? Presented by Keith Oliver Head of International
19 A sea of questions 04/04/
20 Preservation of international agreements 04/04/
21 English arbitration clauses 04/04/
22 EU legal framework Recast Judgments Regulation (EU) No. 1215/2012 Lugano Convention 2007 The Hague Choice of Court Convention 2005 Rome I Regulation (EC) No. 593/2008 Rome II Regulation (EC) NO. 864/ /04/
23 Recast Judgments Regulation (EU) No. 1215/ /04/
24 Key EU Instruments Lugano Convention 2007 The Hague Choice of Court Convention /04/
25 Key EU Instruments Rome I Regulation (EC) No. 593/ contractual obligations Rome II Regulation (EC) NO. 864/ non-contractual claims 04/04/
26 Rome I Regulation (EC) No. 593/2008 Upholds the parties choice of English law in contractual relationships UK could continue to apply it by enacting it into domestic law 04/04/
27 Rome II Regulation (EC) No. 864/2007 Possible to incorporate into English law unilaterally 04/04/
28 The break and the business 04/04/
29 Banks fleeing post-brexit (some to Ireland) 04/04/
30 Keith Oliver Head of International Contact: m Tel. +44 (020) DD +44 (020) Mob +44 (0) Address: 15 Fetter Lane London EC4A 1 BW United Kingdom 04/04/
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