Could Ireland credibly threaten to veto an EU-UK trade deal?

For years now, Ireland and the UK have been the best of friends. Very sadly, Brexit is placing the relationship under strain. The positions of the two governments on the Irish border could not be further apart. Ireland is very clear: no trade deal that involves a physical border is acceptable. That obviously implies that the United Kingdom should seek to remain within the European Economic Area, and form a new customs union with the EU.  This would replicate its existing trade ties with the bloc, while respecting the vote to leave the EU, and avoid the need for a border within Ireland. The United Kingdom, on its part, is adamant that it must leave the customs union in order to strike separate trade deals with the United States and other countries overseas.  To be sure, it pays lip service to the importance of avoiding a border between Northern Ireland and the Republic, but this appears to be nothing more than a cynical manoeuvre. On the one hand, the magical unrealist tendency within the British government appears to think that by talking up the border issue, they can undermine the EU customs union, which has been defined by a common external tariff barrier since the 1950s. This would allow the UK to have its cake and eat it. On the other hand, the lip service will, they hope, allow the UK to place the blame for the consequences of its own decisions on Ireland and the rest of the EU.

What, if anything, can Ireland do?  As has been noted recently, the country is not powerless. While the withdrawal agreement between the UK and EU will be decided by qualified majority vote, Ireland does have a potential veto in at least two possibly relevant circumstances. First, it would have a veto should the UK seek to extend the two-year deadline for exit following its Article 50 notification.  Second, and probably more to the point, if as seems likely the UK ultimately seeks an ambitious, “mixed” trade deal with the EU that includes provisions on, for example, investment, Ireland will have a veto on that as well.

The UK therefore has the power to give Ireland something that we want: the maintenance of a border-free Ireland. There are encouraging signs that some in Britain may now be moving in that direction, but they are not currently the ones driving British policy. And down the line, Ireland will have the power to deny the UK something that it wants: a trade deal with the EU that goes beyond tariff-free trade in goods, and includes the kinds of provisions on portfolio investment that would be of interest to the City. The question therefore is: can Ireland credibly threaten to use this power in an attempt to prevent the reimposition of a border on our island?

At first sight, the answer seems obvious. We have an interest in maintaining close trade relations with Britain, and so any threat to veto a trade deal between the EU and UK that did not avoid a hard Irish border would be incredible. And perhaps that is the right answer. But I still think it’s worth posing the question.

If there is no trade agreement between the UK and EU, trade between the two parties will be governed by WTO rules. In this hardest of all Brexits, substantial costs will be imposed on Ireland. The two that have received most attention to date are the reimposition of a border, and the substantial damage that will be done to sectors exporting to the UK, particularly food and agri-business.

But now let us consider an alternative scenario, in which the EU and UK sign some sort of a trade deal, but in which the UK also leaves the customs union in order to do separate trade deals with the US, Australia, and so forth. Once the UK does this, a border immediately becomes inevitable: the first major cost of a no-deal Brexit, from an Irish perspective, will be incurred in full, trade deal or no trade deal. Furthermore, once Liam Fox signs separate UK trade deals with cheap food producers overseas, Irish food exporters to the British market will find themselves being severely undercut. The second major cost to us of a no-deal Brexit, the loss of agricultural markets in Britain, may well come about to a large extent, whether or not there is an EU-UK trade deal. Taking both points together, it may be that the opportunity cost to Ireland of a no-deal Brexit may be smaller than we sometimes think, if we start from a scenario where the UK leaves the customs union in order to strike deals with the US and similar countries around the world.

And there are countervailing benefits to Ireland of a no-deal Brexit that have to be set against these opportunity costs: increased inward FDI flows by UK-based firms seeking to export to the EU; and increased costs imposed on the UK economy, which may in time lead that country to apply to rejoin the EU on terms more beneficial to us than the status quo (since they will no longer enjoy their budget rebate).

Yes, we want a close trading relationship with our nearest neighbour, but right now that neighbour is planning to (a) reimpose a border on our island, and (b) sign trade deals that threaten to displace Irish exporters from its market. In my view, the ESRI should not only be modelling the impact of various EU-UK trade deal scenarios on the Irish economy; it should also be modelling the impact on Ireland of the trade deals that the UK may eventually sign with the rest of the world. Opportunity costs are what matter when making decisions, and the net opportunity cost to Ireland of a no-deal Brexit may be smaller than what we sometimes assume, if the alternative involves the UK following through on its current plans. I’d be interested to know how large it would actually be.

And maybe the Irish government should consider playing hard ball in its continuing attempts to avoid the reimposition of a border in Ireland.

 

 

 

 

 

33 replies on “Could Ireland credibly threaten to veto an EU-UK trade deal?”

Absolutely, Ireland has nothing to lose except its temerity.
A hard Brexit, as the article correctly points out, means we are back to hard borders, hard men, customs posts, delays, and quasi strangulation for goods transiting the UK; and the loss of UK food market to non-EU imports, if the UK gets its way.
Ireland has a veto in two crucial areas, and Ireland should use that veto.
If you are going to get shafted anyway, the time for playing Mr Reasonable is over.
Walloon the two year extension, and walloon any services agreement, and announce the intention to do so.
There is no point holding the knave, until the last card is being played. The ‘game’ will be lost at that point.

PS In ideal circumstances, Barnier should be the person doing the running, but ..but.

This comment is based on a misreading of Article 50. The negotiations of the withdrawal agreement are conducted by the Commision on the basis of guidelines established by the European Council, which acts on the basis of consensus i.e. unanimously. When agreed, this is to be concluded i.e. signed off on by the Council [of Ministers], acting by an enhanced QMV after obtaining the consent of the European Parliament. No – formal – ratification by national parliaments is required.
Cf. the relevant sections of the existing (29 April) guidelines.
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II. 5. While an agreement on a future relationship between the Union and the United Kingdom as such can only be finalised and concluded once the United Kingdom has become a third country, Article 50 TEU requires to take account of the framework for its future relationship with the Union in the arrangements for withdrawal. To this end, an overall understanding on the framework for the future relationship should be identified during a second phase of the negotiations under Article 50 TEU. We stand ready to engage in preliminary and preparatory discussions to this end in the context of negotiations under Article 50 TEU, as soon as the European Council decides that sufficient progress has been made in the first phase towards reaching a satisfactory agreement on the arrangements for an orderly withdrawal.

II. 6. To the extent necessary and legally possible, the negotiations may also seek to determine transitional arrangements which are in the interest of the Union and, as appropriate, to provide for bridges towards the foreseeable framework for the future relationship in the light of the progress made. Any such transitional arrangements must be clearly defined, limited in time, and subject to effective enforcement mechanisms. Should a time-limited prolongation of Union acquis be considered, this would require existing Union regulatory, budgetary, supervisory, judiciary and enforcement instruments and structures to apply.

I’m not talking about the withdrawal agreement, and indeed explicitly say that QMV applies there. Nor am I talking about transitional arrangements. I am talking about a new long term trading relationship between the EU and UK, where article 207 will apply. Preliminary and preparatory discussions are one thing, negotiating and ratifying a new trade deal with a third country is another.

From your comment.

“What, if anything, can Ireland do? As has been noted recently, the country is not powerless. While the withdrawal agreement between the UK and EU will be decided by qualified majority vote, Ireland does have a potential veto in at least two possibly relevant circumstances. First, it would have a veto should the UK seek to extend the two-year deadline for exit following its Article 50 notification. Second, and probably more to the point, if as seems likely the UK seeks a trade deal with the EU that includes services, Ireland will have a veto on that as well.”

Sorry to be so blunt but none of the above is accurate. While there is a possibility that the EP (with the participation of Farage, incidentally) and the ministers in the Council [of Foreign Ministers] might overturn an agreement by their Heads of State and Government, it is remote. (What the Mother of Parliaments does is another matter).
The UK is most unlikely to seek an extension of the negotiating period and the EU27 as a bloc are unlikely to agree if it did.
A recent decision by the ECJ on the Singapore FTA confirmed that only a few definable cases existed for classifying trade agreements as “mixed”. Inclusion of certain elements e.g. audiovisual (l’exception francaise) might make them subject to unanimity in the Council. The answer in both cases is simple; leave these elements out. But this is far in the future (hopefully).
FOT should stick to theatre reviews.

“The UK is most unlikely to seek an extension of the negotiating period and the EU27 as a bloc are unlikely to agree if it did.”

But unanimity is required for any extension of two year period. That is what article 50 (3) says. So, Ireland does have a veto on an extension, if no withdrawal agreement is in place before March 2019.

The withdrawal agreement may be nothing more than a one page document, but it must be in place by March 2019 in order to avoid a cliff-edge exit.

Further if the UK wants an extension of the staus quo, in the absence of, or difficulty with, getting a withdrawal agreement, then the rules must stay the same., albeit these rules are simply negotiating guidelines. [Extract from above: “Should a time-limited prolongation of Union acquis be considered, this would require existing Union regulatory, budgetary, supervisory, judiciary and enforcement instruments and structures to apply.”]

On the issue of Ireland’s latitude in relation to a new agreement on services, how was it that the Walloon assembly on its own was able to stymie an agreement?

General:
One cannot help but notice that the EU position has moved from an immediate and unsavory good riddance approach, best encapsulated by Juncker’s remarks to Farage ‘What are you still doing here’, to an approach where the seemingly plain English of the text is being stretched to the limit, to provide an out at the end of the two year period.

This is all very well, and good realpolitik, provided Ireland’s strategic interest of no hard border is safe. (i.e UK in the customs union, at a minimum, even though that will still cause cause considerable disruption)
However, while the current UK government stills insists on leaving the customs union, Ireland should make it known that we will play whatever veto is open to us.

If the UK leaves the customs union, Ireland is goosed anyway; goosed on two fronts, loss of market for existing products into the UK, and competition from Non EU producers for agri-food products, and KOR is correct in saying that loss on both issues need to be considered.

There is little doubt that the Irish (EU) border issue is being used by the UK, to attempt to soften the EU stance. And there is little doubt that the Irish (EU) border issue is being used by the EU to flush the UK out of its initial position. [I concede that the EU has been quite masterful in its approach and tactics, particularly in using the Irish border issue to flush the UK out.]

But Ireland is therefore being used both as both the theatre of conflict, and perhaps a bargaining chip, and if you allow yourself to be used as a bargaining chip, you end up being bargained.

In those circumstances, Ireland should have no compunction about using whatever veto is available to us.

@ JR. One step at a time! The extract you quote illustrates how ahead of the game the drafters of the guidelines were. The Walloons were able to block CETA because it WAS a mixed agreement. This is also the conclusion of the ECJ with regard to the Singapore agreement, but if defines in its judgement, and narrows, the elements that are shared competences with the member states (i.e. the elements that make it mixed).
The point I was making is that it is quite possible to draft a comprehensive FTA between the EU and the UK free of these elements; if matters ever get to that point.
The EU is a union of law. This is Ireland’s strongest card. The UK has been attempting, since May came to power, to use its power status to strong-arm a deal past the EU’s legal procedures.
Throwing threats of vetos around, a perennial failing of the Irish body politic, is counterproductive. It plays the UK game. The concept does not exist in EU law. Matters are decided by (i) consensus i.e. unanimity with no set voting procedure (ii) unanimity in the context of set voting procedures or (iii) qualified majority voting ditto.
It is ironic, to say the least, that the UK establishment, media included, will be experts in the workings of the EU by the time Brexit takes place, assuming it takes place. As will be the case in Ireland and, indeed, other EU countries most impacted by Brexit.
As George Parker of the FT commented on RTE radio, the ardent Brexit brigade are looking forward to “independence day” on 29 March 2019 and are “keeping their discipline” i.e. they want the UK formally out of the UK and care little for the circumstances surrounding its exit. The will have swapped the reality of sovereignty in the modern world for the isolated trappings of it. Of course, someone is bound to point out that the date in question is a cut-off date i.e. it ONLY applies in the event of NO agreement being reached . The economic implications of such an outcome should be even more obvious by the.
As to extending the period, I quote to you again Napoleon; “Never interfere with an enemy when he is making a mistake”.

And again: absolutley! The factions currently in charge in the UK would damage Ireland without a second thought. Indeed they’ve already done that with the referendum vote. Palmerston’s famous statement about friends, enemies and interests is as applicable to Ireland as it ever was to England/the UK. And frankly, the typical Briton, whether a supporter of leave or remain, would regard us as fools if we declined to use every power at our disposal to protect our interests and would respect us more for flexing our muscles than for being weak and conciliatory. We don’t have to be unfriendly or difficult towards the UK, just pragmatic and honest about where we see our interests and acting openly in accord with them. Varadkar has made a good start in that regard. I trust we will keep it up.

Talk of vetoes at this early stage of the negotiations is rather premature, to say the least. Equally, hunting around for supposed opportunities for doing so. Brexit is a momentous decision affecting 28 countries, none more so than Ireland. This is how the person doing the deciding put it.

“We [the European Council] will decide whether the UK has made sufficient progress when it comes to citizens’ rights, the financial settlement and issues pertaining to Ireland and only if we are satisfied that sufficient progress has been made on those three areas will we then give the go-ahead to talk about trade.

“I think that puts us in a strong position so I doubt our European colleagues would come to the view that sufficient progress had been made if we didn’t think so”.

text from Blind Biddy:

Yes. The potential tactics of How? remains confidential at the mo.

Hi, thank you for your blog, which I read regularly and almost always learn something.

I suggest Ireland make a public offer to let N Ireland join the south in a union like Scotland and the UK, with full autonomy and freedom to return to the UK at any time. So no customs barrier btw Ireland and N Ireland. But there would be a customs border with the rest of U.K.

I’m not Irish, British nor European. Just an external observer, and I hope impartial!

Kien

Rumours of Labour in Britain now supporting a long transition and discussion of remaining in Single Market. Interesting times

Ireland needs to do the utmost here, and other countries, while not favouring Ireland as such, will recognise the need for a country to do so

It is more than a rumour as we now know.
On the issue of the likelihood of the UK being able to find alternative markets to the EU, could I recommend an outstanding paper by John Temple Lang avaiable on the IIEA website. (There appears to be a difficulty with links on this blog).
The shift in Labour’s position also includes continued membership of the CU.
Of interest, this item culled from the Open Europe website.
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Australia’s Foreign Minister calls for equal treatment under UK immigration plans
The Times reports [18 August] that Australian Foreign Minister, Julie Bishop, has warned of disappointment if the UK imposes more restrictive requirements on Australian citizens arriving in the UK after Brexit than on EU immigrants. Another Australian government source added that these concerns were also shared by New Zealand and Canada and would be raised in any trade talks with the UK. The Times also writes that other Commonwealth countries have privately warned the UK that proposals to allow EU citizens visa-free travel to the UK would discriminate against their citizens, who require visas to enter. An adviser to the Indian government stressed, “Mobility issues are of importance to us. We cannot separate free movement of people from the free flow of goods, services and investments.”

Screw the UK – if we need to use a veto, let’s use it. They have 800 year history of screwing us every chance they get, so why should we be shy?

Shooting ourselves in the head by allowing a local historical quarrel decide our actions in a broader European context? There are many examples of such behaviour right across the EU. It was set up to stop them.

I’m not advocating shooting ourselves in the foot just for spite (the British did that to themselves already) – I’m saying we should not hesitate to use our veto to insure our interests.

I’m tired of us deferring/genuflecting to our nearest neighbors. Unfortunately, there is still an element of Irish society that believes all things British are best and that we can’t survive without them.

As I have explained above, there is no such thing as “our veto” in an EU context. Any attempt to use an non-existent veto right, especially for reasons not associated with reasoned argument, will get the treatment it deserves i.e. either being rejected or, more likely, being ignored.

A free trade agreement in goods would be in the interest of the EU while the deindustrialised UK chances its luck in making deals in the rest of the world – Denmark’s services exports to China are higher than the UK’s and there is little appetite for UK services in the emerging economies.

Ireland is the only EU country where the UK trades with a significant goods surplus while there is a big goods trade deficit with with Germany.

Much of the UK-EU trade is into supply chains and the British should be keen to maintain its reduced industrial base.

Bewildering maybe, but hardly surprising given that he advocated withdrawal from eurozone etc since 2011 without adverting to any potential negative outcomes for Ireland. Same hymnsheet, slightly different tune this time.

Simplistic solutions always appear superficially attractive and Ray Kinsella is entitled to make his case as he sees fit. Whether he’s entitled to ignore the counterarguments to his deeply-held views is another matter.Happily, there’s no shortage of economists – like yourself – with capacity to point to the flaws in his argument which, unfortunately, comes across as imbued with a rather strange nativist sentiment. Further, the Irexit lobby appear unlikely to gain much political traction any time soon.

Veronica, we all must be clearly mindful of our situation. We are an Island. We are the sole member of the EU with a land frontier with the UK. We (and the UK) are Anglophones – we are by no stretch of the imagination, Europeans, no matter what the Illuminati preach from their pulpits. Many of us may have grandiose ideas about the European bit. But the mainland Europeans would simply sneer at us. As far as they are concerned we are simply ex-Britians. And about as reliable as a stick of sweaty gelly. The EU wallahs have already decided the outcome of the negotiations. They want their EU entire cake, and they will not share it out. As for the GFA; that’s a problem for us, the Brits and the two tribes up above.

So. There are two scenarios; [A]: the EU and the UK strike a deal which obviates the need for a physical frontier between the UK and the EU – goods and folk can pass, with some minor caveats; or, [B] the EU and UK fall-out and the EU mandates a physical frontier between the EU and the UK.

If its A, we are saved. However, if its B then where is that physical frontier going to be? Because, the EU will insist on a physical frontier – somewhere. I reckon that they will choose the major air and sea ports of mainland europe – much easier to police. And that leaves us where? In Sh*tsville, is where.

Kinsella may be as daft as a brush and his message wonky – but its not completely devoid of sense.

Brian: I’m glad you spotted the job description at the end of the article. I think the IT editors should be made publish a clarification.

Michael – we ARE a very junior partner in the EU and our taxpayers and their dependents have been compelled (at ATM point!) to pay for this somewhat, increasingly dubious, priviledge. The EU is not a democratic entity, nor cannot be – despite the Alternate Facts printed on the tin. We are an island. We are not a part of the EU Mainland. We cannot be ‘cast adrift’ by the EU – we are slightly adrift already and the tether looks a bit frazzled.

Our parliamentarians will just have to make up their collective mind about the re-imposition (or not) of a physical frontier on this Island. They seem sh*t scared about this and are making increasingly frantic attempts to displace the responsibility for their cowardly non-decision onto anyone or anything they can grasp at. Hurricane Harvey is looking useful.

“The strong will do what they will. The weak will suffer what they must.” A UK operated Procrustian bed may be less severe on us than the EU operated one. Or is it just TINA time again …. and again, and again? Until ….. What? Our economy regresses another two decades?

The Times (always reliable on Tory party twists and turns; I wonder why?) reported today that Prime Minister Theresa May is “planning to go over the heads of Commission officials and deal directly with leaders”. She will reportedly tell them in October that she’s prepared to make a substantial financial payment but as part of a package that allows “significant” single market access and a customs deal during the transition. She may also approach leaders individually beforehand.(It seems yet to have failed to register with her, or her advisers, that Barnier is the EU27’s legally appointed negotiator and that they CANNOT be seen to disown him, or the head of the Commission).

It had not actually hit me until recently that the UK’s insistence on its strategy of “money for access to the single market” had morphed from a negotiating ploy, exercised from an imagined position of strength, to an absolute administrative and economic, and hence, political, necessity; for the UK!

Equally, that the main reason for this lies in the fact that the 29 March 2019 has morphed from being a deadline which only applies in the event of NO agreement into one that applies WITH or WITHOUT an agreement; “Independence Day” has become a political if not a legal reality.

In short; the Conservatives have boxed themselves in. The way things are going, practically anything could happen. North Korea on one side of the world, Harvey on the other, closing down 15% to 20% of US refining capacity. Professor Kinsella may live in a dream world but the country can hardly afford to. Nevertheless, the slightly OTT reaction to his article is symptomatic of a real economic concern in Ireland. The way things are going, however, the UK will not be leaving the embrace of the EU just yet.

It is also worth noting that the drafters of the Article 50 negotiating guidelines could see ahead cf. last sentence of Para II.6.
“Should a time-limited prolongation of Union acquis be considered, this would require existing Union regulatory, budgetary, supervisory, judiciary and enforcement instruments and structures to apply.”
That is all that can be done in the time available.
The UK “without a vote”, i.e.no longer at the table but still on the menu, in such circumstances is, in my opinion, politically impossible for the Conservatives to sell.
On the other hand, crashing out into the arms of the WTO on 29 March 2019, if enormously difficult for Ireland, would risk an even bigger, possibly including a currency, crisis, for the UK.

Good post, Kevin. Ireland is somewhat damned if it does, damned if it doesn’t. The usual approach is the path of least resistance – keep the head down and hope that Ireland is too small in the overall EU/EZ context to warrant too much real scrutiny (continue to live in the cracks’ strategy). That approach may not (will likely not) work this time, and a small part of the tail (Ireland) will not be allowed to wag the dog. I fear that Ireland’s voice will not get much of a hearing in continental Europe, certainly not from the French based on past experience and, unfortunately too, not from the Germans either…too many bigger priorities and problems. So a re-established border seems like the default situation with some “pay-offs” in there to keep people quiet in the short term. The problem of course is that the structural impact of that as outlined by Kevin will be permanent and severe in the longer term, particularly on domestic food & agri, exporters, tourism (already being affected by FX), etc. Once that genie is out of the bottle, there’s no turning back either….no appeal. As Ray Kinsella alludes to, there will be no fighting of what will then be an “old battle”. The EU /EZ super-tanker will not turn very much and very slowly at best. It will be a fait accompli.

The problem too in Ireland is that Government/political and public service incumbents will not be personally too perturbed…..jobs for life, pensions, seniority, EU jobs for some, etc continue so no rocking of the boat will be forthcoming from the “ruling” political class and public sector. Kevin’s post appeals to some national leadership but, in reality, it has always (in modern times) been more personal – “I’m alright, Jack”, “Too small an island for everyone anyway”, etc.

Longer term too will be the challenge of retaining the MNC presence in Ireland. Not black or white positive or negative in the short term. However, LT the risks are firmly weighted to the negative. I heard some Big 4 advisers recently very focused on the short term benefits…to them….and they will be retired before the LT!….again, it’s “I’m alright, Jack” rather than any focus or sense of national pride, even old style nationalism or even a modern state or coherent societal strategy!

So I suppose, there will be winners and losers again. And unless there is a material number of losers compared to winners (and that is challenged already given how great a % the public sector and social welfare elements are in the economy, and even those tied to the FDI sector are largely focused/prioritized elsewhere), then it’s hard to see Ireland leading a charge to block the border against its EU/EX masters’ wishes (or in reality the default consequence of Brexit).

Nothing cynical in saying any of that. Reflects reality and the complexity of societal interests involved in my view. The reality is that Ireland doesn’t have much real leadership “in the national interest”. However, it’s not the only country like that!

It also brings up the extent of embedded “socialism” in Ireland (and Europe) which underpins what Mr. Hunt frequently refers to as “rent seeking” Ireland. While I mention politicians, public sector, social welfare recipients, etc, I think it fair to say also that almost everyone in Ireland (South or North of the border) is “sucking on the teat” in one way of the other. Paul H. points clearly to the fact that certain groups are more expert (or embedded I would say) in extracting freebees e.g. everyone (almost) – when was the last time anyone gave back their Children’s Allowance “entitlement”? Even enjoyed by people on large six figure + salaries/incomes. So, to an extent, the whole system (everyone) is firmly aimed at not rocking any boat if they can avoid it….So long as there are more winners (“rent seekers”) than losers, Irish historical “landlordism” lives on in the “rent seeker” Irish nation state (which is obviously attractive to many immigrants too….another subject, but some cross-over).

So Kevin, my money is on a hard border, by default.

Apologies if I cannot engage timely in any further debate tomorrow. I’m in a very different time zone.

There is no need for political histrionics from the Irish government or trying to portray Brexit as some sort of disaster about to hit Ireland. The position of the Irish government should be that Ireland has nothing to fear from Brexit but that Britain has, and that as a good neighbour Ireland is happy to point this out to her British friends in the hope that they’ll see sense, while accepting that at the end of the day its their choice whether to harm themselves or not.

The Irish government acting as if Brexit will wreak terrible damage on the Irish economy, and going down on their knees begging Britain not to inflict that damage, will only be interpreted as weakness by Brexiteers. Self-confidence about Ireland’s ability to deal with Brexit should be the hallmark of government statements on the issue. It should concentrate on pointing out the disadvantages off Brexit that Britain will now experience and which Ireland is avoiding.

One of them is the collapse in £sterling. This is about to result in an inflation tsunami in Britain. I went to Iceland last week and it cost me 25% more than a similar trip last year. Someone travelling from Donegal would have seen no increase at all. Between 2007 and 2015 real wages in the UK fell by 10%, the worst performance after Greece. In Ireland they rose by 3%. Undoubtedly this trend has accelerated sharply since 2015 as a result of the 25% fall in £sterling v the euro since early 2016.

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