May 13, 2016 “BREXIT BITES” The EU is essentially a common market, as it used to be officially called. Leaving the EU would have an impact on the trade of goods and services between the UK and the EU. It would also have an impact on the trade with other non-EU countries (“third countries”), in particular in all cases where UK companies are acting now under an international legal framework negotiated by the EU as a whole (including the UK as part of it). A visual summary of the scenarios is detailed in this note. Preparing for Brexit: The Impact on Trade with and from the UK Do you engage in UKbased trade flows? NO Do you engage in UKtargeted trade flows? NO NO ISSUES POTENTIAL ISSUES YES YES Possible tariffs on imports & UK standards to comply with access to market Where is your UK-based trade flow targeted to? TO THIRDCOUNTRIES TO THE EU Cannot benefit from trade agreement negotiated as part of the EU — New trade agreements will have to be negotiated on a standalone basis POSSIBLE EU-UK RELATIONS POST BREXIT AND POTENTIAL ISSUES UK in the European Economic Area • No tariffs on imports towards the EU • Subject to EU standards with no power to influence them • Full access to the EU single market UK signs a Free Trade Agreement • No tariffs on imports towards the EU • Subject to EU standards with no power to influence them • Possible limitations for some sectors, in particular for services For more information, please contact: Ignasi Guardans, +32.(0)2.336.1949 ignasi.guardans@klgates.com Philip Torbøl, +32.(0)2.336.1903 philip.torbol@klgates.com Alessandro Di Mario, +32.(0)2.336.1938 alessandro.dimario@klgates.com UK within the World Trade Organisation K&L Gates Brexit Task Force • New tariffs on imports towards the EU • Need to comply with EU standards Clients can contact the firm with questions about the consequences of Brexit by email at brexit@klgates.com. .

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The information herein should not be used or relied upon in regard to any particular facts or circumstances without first consulting a lawyer. ©2016 K&L Gates LLP. All Rights Reserved. .