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This  article, by Robert Wilkinson appears in the current issue of Communist Review, the theory and discussion journal of the Communist Party
Amidst the cacophony of apocalyptic hysteria surrounding the prospect of failing to come to an agreement with the European Union regarding the terms of UK withdrawal, it has been almost impossible to envisage what a ‘Full Brexit’ would mean.
‘Crashing out’ and ‘cliff edge’ are some of the milder scenarios that are bandied about to frighten the readers of The Guardian into apoplectic convulsions and campaigns to achieve a ‘Peoples Vote’ to reverse the verdict of the Referendum of June 2016.
The fact that there had been a General Election in 2017 in which those parties in Britain that campaigned to Remain in the EU all lost votes (LibDems, Greens, SNP and Plaid Cymru, down over 1.1 million between them) was blithely ignored as too embarrassing to mention.  Even in Northern Ireland, where the pro-EU Sinn Fein increased its vote, what was often overlooked is that the anti-EU DUP increased its vote by a greater amount.  What should also not be disregarded in the euphoria of Labour advance at the national level, is that the party lost 6 seats in which the UKIP vote in 2015 switched almost entirely to the Tories.1 It may well be instructive to pause a while to consider just what was being placed before the electorate in the 2017 General Election. 
The Conservative and Unionist Party Manifesto warned that “The negotiations will undoubtedly be tough, and there will be give and take on both sides, but we continue to believe that no deal is better than a bad deal for the UK”. It went on to proclaim that:
“We will control immigration and secure the entitlements of EU nationals in Britain and British nationals in the EU.  We will maintain the Common Travel Area2 and maintain as frictionless a border as possible for people, goods and services between Northern Ireland and the Republic of Ireland.  Workers’ rights conferred on British citizens from our membership of the EU will remain.  We will pursue free trade with European markets and secure new trade agreements with other countries.  …  As we leave the European Union, we will no longer be members of the single market or customs union but we will seek a deep and special partnership including a comprehensive free trade and customs agreement.”3 (my emphases)
The most significant feature of the 2017 General Election however was that the Conservatives lost their overall majority in the House of Commons, obliging Theresa May to secure a ‘Confidence and Supply Agreement’ with the Democratic Unionist Party of Northern Ireland.
Much has been made of the upsurge of Labour votes of over 3.5 million but it cannot be overlooked that the Conservative vote also increased by over 2.3 million, primarily because the UKIP vote collapsed by over 3 million.4
The Labour Manifesto, For the Many, Not the Few, was praised for its influence on the electorate.  What most interests the argument here is the impact that Chapter 02 ‘Negotiating Brexit’ may have had on the result and the party’s policy since.  It promised to:
“build a close new relationship with the EU … with fresh negotiating priorities that have a strong emphasis on retaining the benefits of the Single Market and the Customs Union – which are essential for maintaining industries, jobs and businesses in Britain.  …  We will build a close co-operative future relationship with the EU, not as members but as partners.”5
It argued in the section on International Trade that:
“The UK’s future prosperity depends on minimising tariff and non-tariff barriers that prevent us from exporting and creating the jobs and economic growth we need.  …  As our trading relationship with the EU changes it is vital that we retain unrestricted access for our goods and services.”6
Free trade costs a high price
The almost universal mantra of the benefits of ‘free trade’ agreements is one that Marxists must question.  As Marx and Engels argued in the Manifesto of the Communist Party, the bourgeoisie in its overthrow of feudalism,
“in place of the numberless and feasible chartered freedoms, has set up that single, unconscionable freedom – Free Trade.  In one word, for exploitation, veiled by religious and political illusions, naked, shameless, direct, brutal exploitation.  …
All old-established national industries have been destroyed or are daily being destroyed.  They are dislodged by new industries, whose introduction becomes a life and death question for all civilised nations, by industries that no longer work up indigenous raw material, but raw material drawn from the remotest zones; industries whose products are consumed, not only at home, but in every quarter of the globe.  …
The cheap prices of its commodities are the heavy artillery with which it batters down all Chinese walls ….  It compels all nations, on pain of extinction, to adopt the bourgeois mode of production; it compels them to introduce what it calls civilisation into their midst, ie to become bourgeois themselves.  In one word, it creates a world after its own image.”7
Oxfam, amongst many other global charities, has exposed the impact of ‘free trade agreements’ on the developing countries.8
By definition a ‘free trade agreement’ enlarges the market and in so doing accelerates the inherent tendency to monopolisation by the producers.  The analysis of imperialism of Hobson, Lenin and Bukharin revealed the growing link between finance capital and the monopoly manufacturers.  The argument proposed by Kautsky that the separate imperialist powers would inevitably merge into a worldwide system of ‘ultra-imperialism’ was decisively rejected by the Bolshevik theorists.  Kautsky had argued that “the time is not far off when those magnates of capital will unite into one world trust which would replace the rivalries and the struggle of nationally limited finance capital by an internationally united finance capital.”  Lenin however countered this argument in no uncertain terms:
“He who denies the sharp tasks of today in the name of dreams about soft tasks of the future becomes an opportunist.  Theoretically it means to fail to base oneself on the developments now going on in real life, to detach oneself from them in the name of dreams.”9
Those who continue to dream that ‘Another EU is possible’, one that exists to overcome the historic conflicts between rival imperialist powers, ignore the realities underlying their mutual support in the face of increased competition from powers outside of Europe.  It is necessary for a complete understanding to reveal that beneath the superficialities of unity there continue to exist profound contradictions.  Bukharin clearly saw that free trade agreements cannot disguise the reality of competition:
“The fact that in individual cases there may be a lowering of the tariffs or mutual concessions stipulated in treaties, does not alter the general rule – all such facts are only exceptions, temporary halts, an armistice in the everlasting war.”
“There is nothing behind the discussions about the creation of a middle European tariff alliance but the wish to create a vast economic territory as a monopoly system allowing more successful competition on the external market.  In reality this is a product of the interests and the ideology of finance capital.”
“To imagine that the trusts, this embodiment of monopoly, have become the bearers of the free trade policy, of peaceful expansion, is a deeply harmful utopian fantasy.”10
Britain’s situation 
The advocacy in the Labour Manifesto of tariff-free access to the EU market cannot ignore the fact that this access would be reciprocal by belonging to ‘a’ customs union (how this would differ from ‘the’ customs union is not fully explained).  Britain’s “unrestricted access” to the EU market would inevitably require the access to the UK market for EU manufacturers.
The overall situation is serious enough that, since 2011/12, the balance of payments has swung decisively against Britain, as shown in Fig 1.11  This cannot be blamed on Brexit uncertainty as there was every expectation by the ruling class prior to 2016 that the Referendum would go in their favour.  In 2016 the deficit widened to 5.9% of GDP, the highest on record.  However, while historically a deficit balance has been largely due to the difference between exports and imports of goods and services, more recently, the primary income deficit has played a more significant role.  Primary income includes income from interest, profits, dividends generated from foreign direct investment (FDI) and portfolio investment, and also migrant remittances, ie payments from people living and working overseas.  Net secondary income includes (for the UK) the annual contributions to the EU, and spending on military aid, overseas development aid etc, so will always be negative.
FIG 1 Annual current account balance. 11
As Fig 1 shows, since 2012 all factors of the balance of payments have been negative.  In terms of economic theory this should have led to a devaluation of sterling but this would not have been in the interests of the financial sector that dominates the UK economy.  The main reason for the fall in primary income is a sharp drop, from about 3.3% to 0.5% of GDP, in FDI, and a sustained negative balance of around 1% of GDP, in portfolio investment.12  The fall in FDI largely reflects a sharp drop in the rate of return.  Traditionally the UK has relied on profits from investments abroad to counterbalance the deficit on foreign trade.  However, the rate of return on FDI assets had already fallen from 8.1% to 5.4% between 2011 and 2014,13 and this trend seems likely to have continued.
FIG 2 Annual composition of the trade balance in goods by trading partner 14
The situation is significantly different when the data is broken down into the relationship between the balance with the EU and the rest of the world.  As Figs 214 and 313 show, the trade balance in goods with the EU has widened significantly while the trade balance in services has deteriorated much more sharply with the EU than with the rest of the world.
Fig 3. Annual composition of the trade balance in services by trading partner.13
Tariff-free relations with the EU are not necessarily in the interests of the UK as wealth is increasingly being siphoned off to the benefit of EU manufacturers and EU investors in the UK.  As Fig 415 displays, the FDI income balance with the rest of the world outside the EU is still positive; countries such as China continue to invest in Britain and UK investments abroad outside the EU are still profitable.
Fig 4. Annual FDI income balance.15
The insistence by much of the political establishment, including most Labour MPs, that the UK must remain a member of the EU Customs Union may not be the conclusion that should be reached on the basis of the information contained in the EU’s own Country Reports.  Tariff-free trade does not necessarily act in favour of a country attempting to preserve and protect its industries from undercutting by foreign competition.  The Labour Manifesto in 2017 saw fit to identify the “dumping of state-subsidised goods on our markets” as a justification for advocating “duties needed to defend the British steel industry”.16
There needs to be much wider application of this principle if UK manufacturing is not to continue to be devastated by EU competition.  The predominace of German manufactures is highly significant – £21.3 bn, ie 32% of the net trade imbalance with the EU, in 2017.17  It is noticeable that although imports of goods from the Republic of Ireland, the Netherlands and Belgium make up a significant proportion of their Gross Domestic Product, exporting to the UK makes up far less of German GDP.  It would be important to consider how easy it would be to replace these imports with domestic manufactures or imports from countries outside the EU.
The 2017 Labour Manifesto did go some way in recognition of the need to restrict absolutely open ‘free trade’ by the promise:
“We will ensure all future trade deals safeguard the right to regulate in the public interests and to protect public services.  Labour is committed to the rules-based international trading system of the World Trade Organisation (WTO).  We will rejoin the Government Procurement Agreement, whilst safeguarding the capacity for public bodies to make procurement decisions in keeping with public policy objectives.”16
These objectives are likely to conflict with EU Directives making continued membership of the Single Market difficult if not impossible.
The growth in world trade has been greater for countries outside the EU.  By 2003 sea freight costs had fallen to half that of 1970.18 In these circumstances it would be suicidal for Britain to remain constrained by the trading deals that the EU has negotiated with other countries rather than taking advantage of the opportunity to develop our relationships with the expanding markets outside the EU.  Remaining within ‘a’ or ‘the’ customs union with the EU would effectively prevent any future government from implementing policies that would be to the benefit of our manufacturing and extractive industries, agriculture, fisheries, commercial and the expanding communication sectors.
The importance of financial services for the UK economy is consistently emphasised in the EU Country Reports.  The 2017 Report drew attention to its role in mitigating the consequences of the growing deficit in trade in manufactured goods (see Fig 3):
“The UK continues to run a substantial trade surplus in services, the majority of which is with countries outside the EU.  A large surplus in financial and pension and insurance services accounts for around half of the services surplus.  The trade surplus in services with the EU, which is considerably smaller than that with the rest of the world, is dominated by a large surplus in financial services, while there is a considerable deficit in travel services.  …  The UK is home to the largest financial sector in the EU and one of the largest in the world.  The financial services sector accounts for around 8% of UK GDP (2014) and 3% of UK employment (September 2016).  …    The surplus in financial services reflects the UK’s sectoral strength in financial services and insurance and pension services, which it has retained for at least the last ten years.”19
The price we pay
Much ridicule has been heaped on the claim emblazoned on the ‘big red bus’ that the UK sent £350m a week to Brussels.  This even went so far in some arguments as to claim that in fact Britain received more from the EU than we paid in contributions.  The claim by Boris Johnson and the ‘Vote Leave’ campaign was of the gross contribution, which did not take into account the ‘rebate’ negotiated by Margaret Thatcher or the EU funding of the public and private sectors.  Nevertheless, even with all these deductions, there is, according to Government statistics, a net contribution of around £7.4 bn a year.20  The figure has risen steadily since accession and the receipts from EU funding have been declining since 2008.21
In 2016 the UK contributed over 13% of the funding for the EU, the third highest after Germany (19%) and France (17%).  The loss of this funding would be considerable, especially upon those EU countries that rely most heavily upon EU grants to keep their economies afloat.22  The largest recipient of EU funding is Poland, which may well explain the hard nosed approach of EU President Donald Tusk to the Brexit negotiations.
If the rebate were ended, the UK would become the second largest contributor to the EU budget.  The level of the rebate has been decided every seven years, as part of the EU’s long-term budget, the Multiannual Financial Framework (MFF).  The new round of negotiations in 2020 is likely to be extremely fraught, as at present the settlement requires unanimity of the European Council.  European Budget Commissioner Gunther Oettinger has argued that the rebates should be scrapped completely:
“I want to propose a budget framework that does not only do without the mother of all rebates [the UK’s] but without all of its children as well.”23
Even if the UK were to remain a member of the EU, there is no guarantee that the rebate in its present form would continue after 2020.  The current procedure of seeking unanimity (effectively giving any government a veto) may well be replaced by Qualified Majority Voting that is becoming increasingly used in the deliberations of the Council of Ministers.
The centre-piece of Britain’s trade policy after Brexit would be membership of the World Trade Organisation and trade with the EU would continue on that basis as a minimum requirement.  A bespoke trade agreement could be negotiated with the EU without locking Britain into a Customs Union that would prevent the UK from making bilateral or multilateral trade agreements with other countries.  Some argue for ‘Norway Plus’ and that Britain should revert to membership of European Free Trade Area (EFTA) as this would not require the UK to be subject to the Common Agricultural Policy, Common Fisheries Policy or the EU Foreign and Defence Policy.  What is overlooked is that membership of EFTA is still subject to Article 45 of the Lisbon Treaty, on freedom of movement and residence,24 and that Norway has a healthy trade surplus with the EU. These are issues that would count against what the majority of Leave voters had sought to achieve.
Another persistent argument by those who seek to retain UK membership of the EU is that the value of sterling has collapsed since the Referendum.  In fact the European Commission’s Country Report of 2016 regarded the relative depreciation of sterling as being beneficial to the UK economy:
“A depreciation of sterling is likely to act as an automatic stabiliser should investor sentiment turn against the UK. A depreciation should spur export growth and reduce import growth and thus, theoretically, reduce the current account deficit. In addition, UK assets denominated in sterling become cheaper in foreign currency terms. As a greater share of the UK’s foreign liabilities is denominated in sterling than is the share in foreign assets, in the event of a depreciation of sterling, the net foreign asset/liability position should improve as a result of valuation effects.”25
Fig 5. Annual nominal effective exchange rate.26
The 2017 Report showed a  depreciation of sterling of around 11% on a trade-weighted basis since 23 June 2016 (Fig 5).26  The decline is considerably less than that between 2007 and 2009, and from a level that was overvalued between 2013 and early 2016, damaging the export of goods and services to the benefit only of the financial sector and UK tourists and the purchase of property abroad.
The Four Freedoms
Britain’s remaining in the EU Single Market would require a recognition of compliance with the ‘Four Freedoms’ envisaged in the original Treaty of Rome and enshrined in the subsequent Treaty of Lisbon that expand the free movement of goods in the Customs Union to the free movement of services, capital and people.  Although it has been the last freedom that has agitated many who seek to remain in the EU since the verdict of the Referendum, it is the free movement of capital required by the Maastricht Treaty that is most significant for the future relationship of Britain with the EU.27
The free movement of persons is defined in EU Directive 2004/38/EC28 that requires European Economic Area (EEA)29 citizens to be able to move freely and reside in any other country.  Free movement includes employment and travel but is not absolute as the migrant must not be a “burden on the social welfare system or public safety” (public security30 or public health).  This means the right to working as an employee (this includes looking for work for a reasonable amount of time31), working as a self-employed person, studying, and being self-sufficient or retired.  It is normally the case that after 5 years the right of residence becomes permanent.
Those who argue that these rights would be lost once the UK leaves the EU usually ignore the fact that these rights are those of EEA membership and not restricted to the European Union.  In any case, as Switzerland shows, they can be negotiated by mutual agreement, especially where transit between one member country and another is a significant amount.32
In addition a considerable proportion of the rights of free movement are an integral part of the European Convention on Human Rights33 agreed by all members of the 47-member Council of Europe and subject to the legal judgements of the European Court of Human Rights.  Although there are elements in the Conservative Party that would seek to withdraw from the ECHR, it is highly doubtful that there would be a House of Commons majority to do so.
Protocol No 4, Article 2 (1963) of the ECHR gives the right to choose residence within the territory of a state and the right to leave a country.  It does not however give any right to enter another country except one’s own, although there are restrictions on the right of any country to expel “aliens” who must be accorded the legal rights to due process of law.34
The focus by campaigners on the rights of individuals is understandable and usually justified as the UK Government is often found to be in breach of Human Rights Conventions.  What must be considered by Marxists is the context in which the exercise of rights occurs.  Every act by every individual has social causes and social consequences.  These cannot be ignored in any analysis with claims to validity.
The EU Commission is quite clear what the social effects of mass migration have been as it has sought to advocate and enable such movements of people for its own purposes.  The EU Single Market Strategy35 was not simply to “revive and modernise the single market in a way that improves the functioning of the markets for products and services”.  Its aim of “‘Upgrading the Single Market” was to enable “more opportunities for people and business”.36  It sought to “improve the functioning of the labour market by promoting mobility between member states” and “contribute to lower prices for professional services”.37  It argued that “the European Union should go a step further and push for deeper integration of national labour markets by facilitating geographical and professional mobility”.  It went on to say that “Not only does labour mobility help close skills gaps and labour shortages, it also balances demand for labour between Member States.”
The ‘macroeconomic’ justification for this EU policy was explained in a 2015 European Commission Quarterly Report on the Euro Area, with the section title ‘Labour mobility as an adjustment mechanism.’38  It argued that:
“The movement of workers from one EU country to another has become an increasingly important adjustment mechanism for the European economy …  This analysis shows that labour mobility increases significantly when a country joins the EU ….  The analysis demonstrates that real wages also become more responsive to asymmetric shocks during the same period. …  [However] cross-country mobility flows were much lower than those recorded in other highly integrated areas, particularly the US,39 … [while] the stock of migrants from within the EU is also generally much lower than from outside the EU.  Nevertheless an upward trend is visible, which is not only the result of the enlargement of the EU to Eastern European countries characterised by high outward migration, but also of movements among old member states.”
The EU countries hosting the largest number of EU migrants in 2010 were Germany, Spain, France, the UK and Italy.  The EU countries with the largest number of people in other EU countries were Romania, Poland, Italy, Germany and the UK.40  As Table 141 shows, the impact upon the ‘new accession countries’ of eastern Europe has been profound and led to a significant loss of their young generation of skilled, healthy and enterprising men and women.  Every individual is an investment for the future, not simply of their own family but of their wider community and society.  Many are skilled in occupations and professions that have been trained at considerable expense and whom their countries could ill afford to lose.  In total the new accession countries saw a fall in their total population of over 7m people since 1990/91.  Even in the case of Poland, where the population did grow slightly by 1%, this was a substantial drop from the 21% growth in the 25 years prior to 1990/91.
There are campaigns in Britain by some well-meaning people that there should be ‘open borders’ to counteract the loss of rights by EU migrants.42  Others in the labour movement have identified that the consequences of such policies have led to a growth of support for far-right and racist attitudes not just in Britain but throughout Europe.  Len McCluskey, at the 2016 Conference of the Centre for Labour and Social Studies (CLASS), argued that:
“We are past the point where working people can be convinced that the free movement of labour has worked for them, their families, their industries and their communities.  It is fine to argue values and perspectives for the middle distance but if it comes up against the reality of people’s daily experience, these arguments will fail.  …  It is all part of the flexible labour market model, ensuring a plentiful supply of cheap labour here for those jobs that can’t be exported elsewhere.”43
The TUC, in its policy statement, Managing migration better for Britain, argued that:
“Voters feel alienated by the pressure that they feel poorly managed immigration has put upon wages, housing and other public services.  …  The TUC has … long called for better regulation of the labour market to prevent employers exploiting free movement rules to get cheap labour and using migrant workers to undercut other workers ….  The TUC has always argued that migration should not be used as a long term solution to skill shortages such as in education and the 130,000 jobs in the NHS currently filled by EU migrants.  These could be filled by local labour with the right training and apprenticeships ….”44
Finally the Labour Manifesto itself argued that “Labour offers fair rules and reasonable management of migration.”  It promised that:
“We will take decisive actions to end the exploitation of migrant labour undercutting workers’ pay and conditions.  We will replace income thresholds with a prohibition on recourse to public funds. We will stop overseas-only recruitment practices.”45
It remains to be seen whether these policies could be accommodated within the obligations laid down by Article 45 of the Treaty on the Functioning of the European Union.46
Notes and References
1 Copeland, Mansfield, Middlesbrough South, North East Derbyshire, Stoke-on-Trent South and Walsall North. Although the aggregate Labour vote increased by 18,609 the Conservative vote increased by 45,012 as the UKIP vote collapsed by 41,376.
2 The Common Travel Area is an open borders area comprising the United Kingdom, the Republic of Ireland, the Isle of Man, and the Channel Islands.
3 The Spectator, 2017 Conservative manifesto: full text, online at https://blogs.spectator.co.uk/2017/05/2017-conservative-manifesto-in-full/.
4 The increase in the Conservative vote was not however reflected in the seats won as they lost 13 constituencies whilst Labour gained 30. Labour may have won back nearly a million (954,610) votes from UKIP.
6 Ibid, p 30.
7 K Marx and F Engels, Manifesto of the Communist Party, in Collected Works, Vol 6, pp 487-8.
8 Oxfam Briefing Paper 61, Dumping on the World: How sugar policies hurt poor countries, online at https://www.oxfam.org/sites/www.oxfam.org/files/bp61_sugar_dumping_0.pdf; also K Ulmer, Are Trade Agreements with the EU beneficial to women in Africa, the Caribbean, and the Pacific?, at https://policy-practice.oxfam.org.uk/publications/are-trade-agreements-with-the-eu-beneficial-to-women-in-africa-the-caribbean-an-131550.
9 Lenin, introduction to N Bukharin, Imperialism and World Economy, Bookmarks, 2003.
10 Bukharin, op cit, pp 79, 80, 152.
11 European Commission, Country Report United Kingdom 2018, p 8; online at https://ec.europa.eu/info/sites/info/files/2018-european-semester-country-report-united-kingdom-en.pdf.
12 European Commission, Country Report United Kingdom 2017, p 22; online at https://ec.europa.eu/info/sites/info/files/2017-european-semester-country-report-united-kingdom-en.pdf.
13 European Commission, Country Report United Kingdom 2016, p 31; online at https://ec.europa.eu/info/sites/info/files/cr_uk_2016_en.pdf.
14 Country Report 2017, op cit, p 6.
15 Country Report 2016, op cit, p 32.
16 For the Many, Not the Few, op cit, p 30.
17 M Ward, Statistics on UK-EU Trade, House of Commons Library, Briefing Paper No 7851, 11 January 2019, p 14; downloadable at https://researchbriefings.parliament.uk/ ResearchBriefing/Summary/CBP-7851#fullreport.
18 E Ortiz-Ospina, D Beltekian and M Roser, Trade and Globalization, 2018 (2014); online at https://ourworldindata.org/trade-and-globalization.
19 Country Report 2017, op cit, pp 7, 16.
20 HM Treasury, European Union Finances 2017, p 12; online at
https://assets.publishing.service.gov.uk/government/uploads/ system/uploads/attachment_data/file/691017/EU_finances_ 2017_Cm9576_web.pdf.
21 M Keep, The UK’s Contribution to the EU Budget, House of Commons Library, Briefing Paper No 7886, 23 November 2018, p 8; downloadable at https://researchbriefings.parliament.uk/ ResearchBriefing/Summary/CBP-7886.
22 Statista, Share of Contributions to the European Union Budget in 2016, by member state, at https://www.statista.com/statistics/ 316691/european-union-eu-budget-share-of-contributions/.
23 Politico, Oettinger wants to scrap all rebates in post-Brexit EU budget, at https://www.politico.eu/article/oettinger-wants-to-scrap-all-rebates-in-post-brexit-eu-budget/.
24 EU Charter for Fundamental Rights, Article 45, at https://fra.europa.eu/en/charterpedia/article/45-freedom-movement-and-residence.
25 Country Report 2016, op cit, p 35.
26 Country Report 2017, op cit, p 5.
28 Online at https://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:L:2004:158:0077:0123:en:PD.
29 The EEA comprises the EU plus the EFTA countries of Iceland, Norway and Liechtenstein. Switzerland is a member of EFTA but not the EEA as it has negotiated a separate bilateral agreement with the EU.
30 The UK and the Republic of Ireland are not part of the Schengen Agreement and reserve the right to monitor the passports of anyone entering the Common Travel Area.
31 What is defined as ‘reasonable’ is up to the courts in each country to decide.
32 Transit is an obvious factor in the case of Switzerland but its importance should not be overlooked in the case of the UK as most of the trade between the Republic of Ireland and the other countries in the EEA transits through Britain and Northern Ireland, and the Open Skies Agreement enables transatlantic flights on the Great Circle route between most EEA countries and North America to overfly the UK.
34 Protocol No 7 Article 1 (1984) and the earlier Protocol No 4 Article 4 (1963). There appears to be breach of these Protocols in the case of the Windrush generation by the UK government.
35 European Commission, The Single Market Strategy, online at http://ec.europa.eu/growth/single-market/strategy_en.
36 European Commission, Upgrading the Single Market: more opportunities for people and business, Com (2015) 550, online at https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-550-EN-F1-1.PDF.
37 See the European Commission’s European Semester Thematic Factsheets on Services Markets and Services, https://ec.europa.eu/info/sites/info/files/file_import/european-semester_thematic-factsheet_services-markets_en.pdf and https://ec.europa.eu/info/sites/info/files/european-semester_thematic-factsheet_services_en.pdf; a specific Factsheet, Regulation of Professional Services (14.11.2016) appears to have been deleted.
38 Online at http://ec.europa.eu/economy_finance/ publications/qr_euro_area/2015/pdf/qrea1_section_2_en.pdf.
39 Only 4% of working age EU citizens lived in another EU country as against 30% in the USA living in a state other than that in which they were born but another 1.1 million worked in another EU country but did not reside there and 1.2 million were posted workers working for their home companies for a limited period of time.
40 C Vargas Silva, EU Migrants in other EU Countries: An Analysis of Bilateral Migrant Stocks, The Migration
Observatory at the University of Oxford, 2012; online at https://migrationobservatory.ox.ac.uk/wp-content/uploads/2016/04/ Briefing-Bilateral_EU_Migrant_Stocks.pdf
41 Data from listings at https://data.worldbank.org/ indicator/ SP.POP.TOTL.
42 Labour Campaign for Free Movement, https://www.labourfreemovement.org/.
43 L McCluskey, Workers need safeguards and strong unions to make migration work, online at Labour List, https://labourlist.org/2016/11/len-mccluskey-workers-need-safeguards-and-strong-unions-to-make-migration-work/.
44 TUC, Managing Migration Better for Britain, pp 2, 5, 7; downloadable at https://www.tuc.org.uk/sites/default/files/ ManagingmigrationbetterforBritain.pdf.
45 For the Many, Not the Few, op cit, p 28.

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