FRM杂谈丨英国脱欧不确定性的影响远超金融服务业
行业资讯 | 2019-03-28
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英国可能会在没有平稳过渡协议的情况下于3月29日离开欧洲——当下许多猜测都围绕着这一可能性将带来的后果展开。没有协议意味着英国将成为其最大贸易伙伴——欧盟的第三国。由于缺乏正式的自由贸易协定，英国和欧盟突然面临需要转而使用世界贸易组织规则的尴尬局面。
除了有限的临时授权外，英国企业将面临20多年前欧盟单一市场出现之前的许多类似挑战，以及自1973年英国加入欧盟以来它们再也未曾面临的关税壁垒和其他挑战。
“这就是为什么至少两年的过渡期非常重要，因为它允许欧盟和英国在此期间就他们不想失去的一切达成一致，同时不破坏这些利益共同点，”多萝西·列文斯顿解释道。利文斯顿是知名的国际律所史密夫斐尔（Herbert Smith Freehills）英国退欧小组的领导人，也是伦敦金融城律师协会金融法委员会主席。她从贸易、运输、供应链、口岸查验和型式批准等多个方面阐述了英国无协议脱欧可能对实体经济造成的种种影响。》》更多金融证书相关问题点我咨询
“不完美的局面”
“If we drop out suddenly and all these things fall away,” Livingston said, “we're left with an imperfect situation that definitely would risk substantial disruption to trade in both goods and services.”
Impeding the withdrawal agreement is the so-called Irish backstop. The provision was designed to prevent a “hard” border between Northern Ireland, a part of the U.K., and the Republic of Ireland, which will continue as an EU member. The U.K. government has been unable to garner sufficient support for the agreement from members of Parliament wary of lingering obligations to the EU, and continuing negotiations in London and with the EU have failed to break the impasse.
Recognizing the stakes, the U.K. last August published extensive instructions on preparing for a no-deal Brexit and has followed up with significant legislation. The European Commission （EC） launched a more streamlined “Contingency Action Plan” last November. On December 19, the EC stated that it had adopted all the legislative proposals and delegated acts announced in the action plan, and that any remaining items would be ready by February 15 “to allow for a vote in competent committees.”
引发实体经济风险
The financial services industry has received significant Brexit-related attention, given its business and economic importance. Livingston said that the U.K. has established a “temporary permissions regime,” enabling a French or German bank branch to continue operating in London for up to two years if it applies for U.K. authorization. But the EU has done little on that front, with the EC's contingency plan limited to providing temporary authorizations focusing on derivative transactions.
Many U.K.-based banks and insurance companies fortunately have EU offices and the proper licenses, Livingston said, and many more are making those arrangements to avoid disruptions to customers.
Other industries face bigger challenges. The EC's contingency plan provides U.K.-controlled airlines with 12-month authorizations to fly across the EU and make stops. However, it restricts cabotage – the transportation of goods or persons between two places in a country. So depending on the final EU legislation, U.K.-controlled airlines may no longer be able to drop off passengers or cargo in an EU airport, pick up more to fill the plane, and travel to another EU destination.
交通枢纽受阻
Airlines are working to minimize disruptions, Livingston said, noting that London's Heathrow Airport is routinely ranked as the busiest airport in Europe, with significant traffic into the EU.
Road haulage and border controls are also likely to suffer from a no-deal.
Livingston noted that the EU's contingency plan would effectively permit a limited amount of road haulage by U.K. carriers into the EU for a period of nine months, but it also restricts cabotage for trucks.
Vehicles will need international permits from the European Conference of Ministers of Transport （ECMT） to replace U.K.-issued EU permits. These have to be applied for in the preceding calendar year, so it is now too late to get one for 2019, Livingston said, and the EU proposal appears to address only the gap before 2020 permits could come into force.
In industries such as trucking, where many businesses are not large and may have limited resources, a no-deal is more likely to cause disruption, Livingston said. She added that the U.K. had announced it intended to permit road haulage with comparatively few restrictions on cabotage, provided the EU reciprocates.
公司供应链可能中断
The EC's limited solutions in areas such as transport are ultimately likely to affect large companies as well, notably auto makers and others with just-in-time manufacturing processes, and retailers relying on just-in-time supply chains.
More commercially damaging, Livingston added, would be the high rates of customs tariffson some agricultural products – upwards of 50% for sheep meat, for example.
口岸查验难题
In fact, ports may be another point of disruption. French ports have traditionally been ports of entry for U.K.-EU trade, but not inspection points for agricultural products coming from outside the EU.
In addition, Livingston said, duties must be paid on automobile parts and other supplies, whichever direction they are moving in. The U.K. has set up a “trusted supplier” scheme in which paperwork is handled off-site and doesn't hold up traffic.
Even if U.K. imports run smoothly, delays to exports at some continental ports could result in significant delays for returning trucks, disrupting supply chains. Simple checks that add 15 minutes to truck or container stays in port can have knock-on effects that cause a backlog.
欧盟型式批准要求
If there is no deal, EU type approvals issued by the U.K. for typically more sophisticated goods such as automobiles, medicines and medical devices – indicating they meet certain EU standards – will not be accepted after March 29.
She added that multinational corporations may already have most of the necessary type approvals for their business in the EU, or have taken steps to get them. Small and mid-size businesses with fewer resources, however, may have been counting on a transition period to complete the task. Given that they are vital links in larger companies' supply chains, the challenges they face will likely ripple through the U.K. and EU economies.
“One would anticipate there to be a whole lot of unexpected problems if we crash out of the EU at the end of March,” Livingston said. Problems that “with the best will in the world people haven't been able to address.”
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