The long arm of Brexit

The effect of Brexit on corporate groups will extend well beyond the sphere of customs duties and VAT. Groups will need to consider the potential effect of the loss of beneficial EU directives on the flows of dividends, interest and royalties. Provisions of domestic law in the UK and the rest of Europe which have been introduced to implement CJEU decisions, including provisions on group relationships, controlled foreign companies, reorganisations, mergers and share exchanges may also be affected by Brexit, with implications for future transactions, current group structures and past periods too.