The UK draft agreement with the EU envisages a free trade agreement and some additional agreements. The EU draft agreement contains broader provisions establishing a new partnership. The EU provisions on state aid and good tax governance will be unattractive to the UK. It seeks to found its position on international not EU norms. On customs, the UK aims to protect manufacturers with global supply chains. Therefore, it aims to broaden the range of goods benefiting from the elimination of tariffs by using ‘extended cumulation of origin’. The areas of dispute are clear. Whether or not they are resolved depends as much on politics as technicalities.
You can read Timothy Lyons QC’s full article for Tax Journal here.