back to article SCISYS sidesteps Brexit: Proposes Irish listing to keep EU space work rolling in

As the wailing and gnashing of teeth over what will become of the UK space industry in a post-Brexit world continues, British firms are sidestepping the flapping of politicians and making their own plans. Bill Murray in the movie Groundhog Day. If you haven't seen it, it's about a man forced to endure reliving the same day …

  1. Dan 55 Silver badge

    The big companies can mitigate this

    It's the small companies I feel sorry for, they either don't have the knowledge to set up in Ireland or elsewhere in the EU or would end up with so many staffing problems that the directors might as well shut down and set up a new company abroad again.

    1. werdsmith Silver badge

      Re: The big companies can mitigate this

      Just move HQ and most of the business to EU and leave a small operation in UK. No point in messing around trying to set up a workaround. Business emigration. It's exactly what the UK government deserve and will get.

      1. Yet Another Anonymous coward Silver badge

        Re: The big companies can mitigate this

        >Just move HQ and most of the business to EU and leave a small operation in UK

        But then you have to hire entirely new staff, in a foreign country, that you don't know if you as a ceo/director will be able to work in come March.

        Much cheaper and easier to get a brass plaque on the wall of an Irish lawyer and nothing else changes.

        1. werdsmith Silver badge

          Re: The big companies can mitigate this

          But they've already got offices and staff in the other countries, they are just shifting the centre of operations.

      2. DavCrav Silver badge

        Re: The big companies can mitigate this

        "It's exactly what the UK government pensioners and people in the north of England and Wales deserve and will get."

        Fixed that for you.

      3. Anonymous Coward
        Anonymous Coward

        Re: The big companies can mitigate this

        >Just move HQ and most of the business to EU and leave a small operation in UK.

        Welcome to the 21st century. Just set up your business online in Estonia...

        https://e-resident.gov.ee/

      4. Alan Brown Silver badge

        Re: The big companies can mitigate this

        "Just move HQ and most of the business to EU and leave a small operation in UK."

        Why bother with the latter part? Brexit means Brexit after all.

  2. Ken 16 Silver badge
    Holmes

    I'm not sure it's that easy

    It will be an interesting example, I know 3rd country banks are required to have an EU Intermediate Holding Company to allow supervision above a certain size but I don't know how it would work with a non financial entity. I'll be surprised if they completely avoid EU taxes.

    1. Saruman the White

      Re: I'm not sure it's that easy

      I don't see why they cannot avoid EU taxes. After all Amazon, Facebook and the likes have been doing just that for years!

      1. Anonymous Coward
        Anonymous Coward

        Re: I'm not sure it's that easy

        They managed to do it by leveraging intra-EU rules, without crossing the tax border to a 3rd party country (well, except when Amazon & others were using the Channel Islands to escape paying VAT - but that didn't fly, they were forced to stop).

        Now they'll have to, it seems likely that things will be different.

    2. Jason Bloomberg Silver badge

      Re: I'm not sure it's that easy

      I would have thought there'd be EU rules in place to prevent taking EU money and simply punting that outside the EU, offloading EU contracts to those with third country status.

      If there aren't; I imagine there soon will be. The EU might tolerate it if we come to some sort of brexit deal with alignment to the EU but I doubt they will if we leave without a deal.

      1. FrogsAndChips Bronze badge
        Pint

        Re: I'm not sure it's that easy

        @Jason: my thoughts exactly, thanks for saving me the post, have this! ->

      2. Scott Broukell

        Re: I'm not sure it's that easy

        "I would have thought there'd be . . ." a get-out clause / provision, with a fully workable formula, agreed, openly discussed and regularly updated by all member states, BUT NO! nobody in the EU ever thought that one day a nation state(s) would want to go it alone! (what the actual f*ck).

        1. Steve Knox Silver badge
          Boffin

          Re: I'm not sure it's that easy

          would have thought there'd be . . ." a get-out clause / provision, with a fully workable formula, agreed, openly discussed and regularly updated by all member states...

          There is: Article 50. It's what allowed Brexit. It's also what allows the EU to say "Fuck You" to any and all requests for equal or special treatment from countries who decide to leave. EU members did think that some might want to go it alone, and they made sure that the EU would not suffer from such selfish behaviour.

          What you're actually complaining about is that there isn't a get-out clause / provision that lets your country get out of the responsibilities of being in the EU while still keeping all of the benefits. Well, I'm sorry, but the rest of the world doesn't exist solely for your benefit. Get over yourself.

          1. Spazturtle Silver badge

            Re: I'm not sure it's that easy

            The EU also suffers if there is no workable agreement made. There are two eventual conclusion to this situation, one where there are 2 winner and one where there are 2 losers.

            1. Steve Knox Silver badge

              Re: I'm not sure it's that easy

              The EU also suffers if there is no workable agreement made.

              True, but you cannot say with a straight face that the EU will suffer as much as the UK, or that they will suffer as much as they would if there were not the framework which allows them to renegotiate trade with those who choose to leave.

              There are two eventual conclusion to this situation, one where there are 2 winner and one where there are 2 losers.

              It's not quite that simple. There is a spectrum of possible outcomes. It is possible for the EU to negotiate agreements which benefit them and harm the UK, just not very likely (although if UK.gov is convinced that the harm of such an agreement is less that the harm they'll incur if they don't agree, it becomes more likely.) It is also possible for the UK to do the opposite, though even less likely. Most likely is that both lose some out of this deal.

              I have to disagree with your representation of the 2-winner conclusion as worthy of inclusion as one of the two major possible conclusions. Brexit is already imposing considerable costs and complexity on the EU-UK relationship on both sides, and the purported regulatory and social freedoms are largely ephemeral. The 2-winner scenario is the least likely of all of the conclusions to this.

          2. Alan Brown Silver badge

            Re: I'm not sure it's that easy

            "EU members did think that some might want to go it alone, and they made sure that the EU would not suffer from such selfish behaviour."

            Ironically enough, this entire section was written by the UK.

      3. Alan Brown Silver badge

        Re: I'm not sure it's that easy

        "I would have thought there'd be EU rules in place to prevent taking EU money and simply punting that outside the EU, offloading EU contracts to those with third country status."

        There are - and also a bunch of rules requiring EU percentage ownership, etc.

        That was mostly a response to the USA's protectionist measures, but it's just as applicable to UK (outside the EU) as to China (who it was targetted at) and the USA.

  3. Slx

    Ireland actually has genuinely huge practical advantages for Brexit fleeing UK companies that are of smaller size.

    1. Speaks English.

    2. Similar common law legal system.

    3. Similar business culture.

    4. UK citizens, even after Brexit, are considered 'non-aliens' in Ireland and thus can live here without any need for work permits, visas or any of that kind of thing due to the Common Travel Area. That won't be changing as it's not an EU based right. It predates it by a long time.

    If they're continuously resident in Ireland for 5 years (which requires no visas/permits for a UK national), then they can apply for Irish citizenship and regain EU status again. Or, if they're married to an Irish citizen, it's reduced to 3 years.

    Or, if you've an Irish grandparent or parent, you can apply for citizenship by descent and get a passport without naturalisation.

    For the majority of UK SMEs, a move to Dublin, Cork, Galway, Limerick or anywhere else shouldn't be much different to a move to Edinburgh or Manchester. It's a different country and legal jurisdiction, but it's about as familiar to a UK person as you could possibly get.

    1. aks Bronze badge

      Move head office to Dundalk (south). Only 14 miles to Newry (north). Wonderful countryside and coast nearby. Trains to Dublin or Belfast. Drive to Dublin Airport in 45 minutes.

  4. Justthefacts

    Well that's weird....

    Having worked in this industry, with Scisys.....

    The entire industry is centred around "georeturn", i.e. contracts go to companies located in countries where their government contributes money towards ESA budget.

    Note, by the way, that ESA membership is nothing to do with the EU. Just another of the things the EU claims that have nothing at all to do with them. For example, Canada is a member of ESA.

    How much money is Irish gov planning to put into ESA from now on? Unless it is more than UK.....

    1. Dan 55 Silver badge

      Re: Well that's weird....

      contracts go to companies located in countries where their government contributes money towards ESA budget

      Note, by the way, that ESA membership is nothing to do with the EU

      Therein lies the problem, who knows what the British government is doing tomorrow, let alone in the short or medium term? Least of all the British government. Some good old-fashioned political stability would be nice, and it just ain't there in the UK.

      ESA and the EU aren't the same, but there was an EU-only clause for the Galileo project put in after lobbying from the UK. Now the UK is leaving they could cut ESA funding because ESA is following the rules and not allowing them to bid for Galileo.

    2. Lars Silver badge
      Happy

      Re: Well that's weird....

      Hello Justthefacts, weird you didn't do some more "fact cheking". And who is this "the EU claims" chap, any link to him you could provide.

      There is more or less what you need on the Wiki: https://en.wikipedia.org/wiki/European_Space_Agency

      Including this.

      "EU and the European Space Agency

      The political perspective of the European Union (EU) was to make ESA an agency of the EU by 2014,[69] although this date was not met. The EU is already the largest single donor to ESA's budget and non-ESA EU states are observers at ESA".

      On Canada.

      Since 1 January 1979, Canada has had the special status of a Cooperating State within ESA. By virtue of this accord, the Canadian Space Agency takes part in ESA's deliberative bodies and decision-making and also in ESA's programmes and activities. Canadian firms can bid for and receive contracts to work on programmes. The accord has a provision ensuring a fair industrial return to Canada.[37] The most recent Cooperation Agreement was signed on 2010-12-15 with a term extending to 2020.[38][39] For 2014, Canada's annual assessed contribution to the ESA general budget was €6,059,449 (CAD$8,559,050).[40] For 2017, Canada has increased its annual contribution to €21,600,000 (CAD$30,000,000).".

      I would assume the UK will eventually apply for something similar.

      And there is of course https://www.esa.int/ESA

      I would suggest you read before you write, I have found it very useful to do it, and at times I have not, which has annoyed me a lot.

      1. Justthefacts

        Re: Well that's weird....

        Do you work in the space industry?

        What actually happened is that the EU made a power-play to take over the ESA competence. ESA Head Worner told them to F* off, and has made very clear that as long as he is in charge, they aren't getting their sticky fingers on ESA. Galileo is the bone that he had to throw them to get the EU to back off.

        This is the world of EU byzantine negotiation. I have spent over a decade of my life playing it at senior levels, and I personally have had enough. You should talk to some people who have actually worked the corridors and coffee points, rather than reading Wiki.

    3. Alan Brown Silver badge

      Re: Well that's weird....

      "Note, by the way, that ESA membership is nothing to do with the EU."

      Indeed, but membership of the high accuracy parts of Gallileo and suchlike DOES have a requirement of being part of the EU - and that extends down to subcontractors, so there isn't a lot that will be allowed to happen in on the British mainland before the people signing the contract cheques get stroppy.

      This "stupid rule" was rammed through by the UK on behalf of the USA, in order to lock China out of Gallileo's military bits. China's response was to say "ah, ok" and revive it's Compass/Beidou 2 plans instead.

      Given that this turn of events took a significant chuck of change out of the Gallileo budgets, ESA and the EU are more than happy to let turn and turn-about be fair play. In most other cases, these "Unfair EU rules" about non-EU members not being allowed to play were actually drawn up by the UK in the first place, so the rest of the EU is engaging in a large degree of quite justified Schadenfreude.

      1. Justthefacts

        Re: Well that's weird....

        I didn't say it was unfair. I was simply pointing out that people who think ESA is EU are incorrect, and (see above) EU are trying to make them correct against the will of the ESA Head.

        I agree that Galileo specifically is an EU program.

        I personally believe that Galileo is a waste of money, but it isn't my money.

        If UK gets locked out of Galileo pork, I personally have no issue with that.

  5. DougS Silver badge

    What if they require some/all the work to be performed in the EU?

    IT outsourcing contracts by federal/state governments in the US almost always require all the work to be done within the US. They may not care if a company with its HQ in Europe like Atos gets the contract, but the people actually performing that work have to be inside the US. Most DoD contracts require the company to be US based AND all the work to be done inside the US.

    If the EU requires the same thing for say Galileo, then technically moving your HQ inside the EU by renting a tiny office in Ireland while the bulk of your company stays in the UK and relisting on a different exchange won't help.

    1. DavCrav Silver badge

      Re: What if they require some/all the work to be performed in the EU?

      They have operations in France and Germany, as the article stated. It's just that their HQ will now be moved into the EU.

  6. Anonymous Coward
    Anonymous Coward

    Desk P0rn

    Pictures of their playout system at Radio 2 here:

    https://mobile.twitter.com/Ladders71/status/1052170495293034496

POST COMMENT House rules

Not a member of The Register? Create a new account here.

  • Enter your comment

  • Add an icon

Anonymous cowards cannot choose their icon

Biting the hand that feeds IT © 1998–2019