CARIFORUM and UK EPA Study

the UK and the EU, and which is likely to be disrupted due to the new customs rules and border disruptions as a result of Brexit. 2. Another consideration relates to Mode 1 cross border supply of services by CARIFORUM firms, which are established in the EU under Mode 3, and which seek to supply services to the UK. These firms may or may not enjoy the same level of preferential access available under either CF-UK EPA, given the provisions of the TCA. 3. The Free circulation/movement of Mode 4 services suppliers employed to commercially established CF firms will also be impacted due to potentially differing or more onerous visa regimes for any given category of temporary entrant, where movement occurs cross border between the UK and the EU. 4. There will also be need for the negotiation of new or separate Mutual Recognition Agreements (MRAs) between UK and CARIFORUM regulators to ensure continuation of the trade in services, so that the flow of service suppliers employed by commercially established CF firms is not disrupted. 5. Consideration will also need to be given to issues surrounding cross-border data transfers between the UK and the EU by commercially established CARIFORUM services providers and the related implications of the EU’s General Data Protection Regulations (GDPR) for Mode 1 trade in services. 6. Issues related to taxation for CARIFORUM firms established in the EU and whether they may need to restructure commercial establishments (ownership/legal form and management requirements) will also be a potential challenge.

ii.

Opportunities

The UK’s strong outward investment orientation is a significant opportunity for CF. CF countries will need to address any structural issues and incentives that are needed for attracting these investment flows. As is consistent with the analysis throughout this report, green investments, and the greening of investments in light of the issues of sustainability and environmental concern has to also be addressed. To date the author is only aware that one CF country has specifically started

Page 20 of 241