Article 50 triggered - what's next for British buyers in Europe?16 June 2017
By the time you read this, Sir Tim Burrow, the United Kingdom’s representative in Brussels will have hand delivered a letter from the British government to the president of the European council, Donald Tusk, stating Britain’s intention to leave the EU.
But what does this mean? How will it affect markets across Europe and the people living there? Below we play out some of the scenarios that will come to pass of the next two years.
Article 50 Invoked, what’s next?
The UK has utilised the four simple paragraphs of the Lisbon Treaty’s Article 50 and now follows two years of negotiations, during which, Theresa May has promised she will negotiate the best deal for everyone in the UK, British or otherwise.
So far it is still also unclear whether or not the UK will remain part of the EEA (European Economic Area) therefore retaining access to the world’s largest single market. Most corners of the government see the UK coming out of the EEA, but retaining access to the market in some form.
After some stuttering today, FX markets expect the pound to normalise fairly quickly. After this, with the inevitable moment coming to pass, over the next few months it’s expected that a better picture of the UK’s future relationship to the EU will be formed, offering some foundation for the pound to return to where it was pre-referendum.
Countries that are part of the EEA are afforded the same rules on tax as those that are part of the EU. Everything from local property taxes and stamp duty to inheritance and capital gains tax will stay the same for at least the next two years.
If the UK comes out of the EEA, EU countries will no longer be required to treat Britons the same way as EU nationals. For countries like France, Spain and Portugal, most taxes are covered by the relatively similar dual-taxation treaties that are in place with the UK, which means that the taxation picture for British buyers and owners in these countries is likely, but not certain, to stay the same.
It’s also worth noting that come the 30th March 2019, both British property buyers and tourists are likely to still be formidable markets for most EU countries therefore to have a country change its tax laws to position that is prohibitive towards inward investment and tourism would be counter-productive.
In theory, the mortgage markets of Britons’ favourite property destinations could change their stance towards buyers from the UK. Using France as an example, mortgage rates there are just above all-time lows and the country can boast amongst the lowest long-term fixed rates available in the world. British buyers here can enjoy loan-to-value rates of up to 85%, requiring only a 15% deposit on a property in France.
For countries outside of both the EU and the EEA, like the US or Canada, they can normally achieve loan-to-value rates in France of up to 70%. Whether or not French banks will change their stance will be discovered over the next 24 months, but again, with British buyers representing such an important part of their non-resident market, a move to make access to property finance difficult and prohibitive is unlikely.
The same is true for Spain and Portugal, where right now British buyers can receive slightly better property finance products than buyers outside the EU.
Potential timeline of events
29 March, 2017 - Article 50 triggered by UK
29 April - 27 leaders of the EU will meet at a summit (without the UK) to agree to provide the European Commission with a mandate to negotiate with the UK
May/June - The European Commission publishes guidelines for the negotiating procedure, based on the mandate, possibly including a note on a parallel negotiations regarding access to the single market
May/June - Negotiations begin
23 April & 7 May - Presidential elections in France
24 September - Parliamentary elections in Germany
November - The UK government will provide legislation on how to leave the EU, changing and combining EU/UK laws where suitable - this is know as the Great Repeal Bill
November 2018 - Negotiations finalised
By March 2019 - The UK’s Houses of Parliament, the European Council and European Parliament vote on any deal - if no agreement can be found, under Article 50 all sides can agree on an extension, subject to approval from the 27 member states
March 2019 - UK formally withdraws from the European Union
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If you have any questions relating to how Brexit will affect your property investment in Europe, please feel free to get in touch with one of our experts today.
|November||The UK government will provide legislation on how to leave the EU, changing and combining EU/UK laws where suitable - this is know as the Great Repeal Bill|
|November 2018||Negotiations finalised|