Relations with UK
The United Kingdom (UK) left the EU and the European Economic Area (EEA) on January 31, 2020. The EU and UK agreed on a transition period during which the UK continued to be treated as an EU member. This transition period, which also applied in Liechtenstein, expired on December 31, 2020.
As of January 1, 2021, UK has become a third country. For future relations, UK has opted for a free trade agreement and against a closer integration model with the EU.
Agreement with UK
Separation Agreement between EEA/EFTA States and UK
The separation agreement, which was provisionally applied as of February 1, 2020 and entered into force on 14. December 2020, ensures that EEA/EFTA nationals already living in the UK, or UK nationals living in Norway, Iceland or Liechtenstein, have mostly the same rights as before. These include residency rights, social security entitlements and recognition of professional qualifications. Since Norway, Iceland and Liechtenstein are part of the single market, the agreement addresses other issues arising from the UK's EU exit, such as data protection, intellectual property, goods already placed on the market and public procurement, in addition to citizenship rights. For all of these issues, the agreement essentially provides that rights acquired before the end of the transition period will continue to be protected or that proceedings still in progress at the end of the transition period will be terminated under the same provisions under which they were commenced. The separation agreement applies only to matters that existed before or on December 31, 2020. It does not govern future relations with the UK.
For more information, see Report and Motion concerning the Withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the EEA Agreement No. 139/2019 (in German).
Additional Agreement to the Trade Agreement between Switzerland and the UK
Economic relations between Liechtenstein and the EU, and thus between Liechtenstein and the UK, have been governed for the past more than 25 years by the Free Trade Agreement between Switzerland and the EU of July 22, 1972, in addition to the EEA Agreement. The Free Trade Agreement creates a free trade area for industrial products. This agreement was extended to Liechtenstein, as was later the agricultural agreement between Switzerland and the EU. On December 31, 2020, both of these agreements lost their applicability to the UK. Switzerland has concluded a trade agreement with the UK that continues a total of six of the bilateral agreements between Switzerland and the EU in relation to the UK. Two of these agreements - the free trade agreement and the agricultural agreement - are extended to Liechtenstein via an additional agreement, analogous to the two Switzerland-EU agreements. The supplementary agreement ensures the continuation of duty-free trade in industrial products and processed agricultural products. The Landtag approved the supplementary agreement on November 6, 2020. It entered into force on January 1, 2021.
Other agreements covered by the Switzerland-UK trade agreement become applicable to Liechtenstein via the customs treaty. Information on these agreements can be found at www.seco.admin.ch and www.ezv.admin.ch.
Free trade agreement between Iceland, Liechtenstein, Norway and UK
The free trade agreement, which was signed in London on July 8, 2021 and entered into force on September 1, 2022 completes the reorganization of economic relations with UK. In addition to cross-border trade in services, including financial services, it also covers areas such as investment, intellectual property protection, digital trade, capital movements and public procurement. In particular, the agreement prevents discrimination against companies from the EU and offers Liechtenstein economic operators preferential market access compared to countries that do not have an agreement with the UK. It ensures legal certainty for access to the UK market and is the most comprehensive free trade agreement Liechtenstein has concluded to date. In terms of content as well as structure, it is based on the Trade and Cooperation Agreement between the EU and the UK.
The original English text of the agreement is available at https://www.efta.int/free-trade/free-trade-agreements/uk. For more information, see Report and Motion concerning the Free Trade Agreement between Iceland, the Principality of Liechtenstein,the Kingdom of Norway and the United Kingdom of Great Britain and Northern Ireland (in German).
Convention on Social Security Coordination between Iceland, Liechtenstein, Norway and the United Kingdom
The Convention on Social Security Coordination, which was signed in London on June 30, 2023 and entered into force on January 1, 2024, is intended to ensure that persons who settle or establish their residence in one of the contracting states for professional reasons are not disadvantaged in terms of social insurance. To this end, it grants persons falling within its scope largely equal treatment and facilitates access to the benefits of the contracting states, in particular by taking into account periods of insurance completed in the other state for the acquisition of benefit entitlements. The agreement ensures the payment of benefits abroad and institutionalizes cooperation between the authorities of the contracting states. In addition, the agreement aims to promote the mobility of persons and avoid double subordination by defining the applicable legal provisions for employees who have a connection to one of the EEA/EFTA states and the UK.
For more information, see Report and Motion concerning the Convention on Social Security Coordination between Iceland, the Principality of Liechtenstein, the Kingdom of Norway and the United Kingdom of Great Britain and Northern Ireland (in German).
Further links:
Information from the UK government: https://www.gov.uk/transition
Information on the new immigration system in UK: www.gov.uk/guidance/new-immigration-system-what-you-need-to-know
Information from the UK financial regulators on the Temporary Permissions Regime (TPR) for financial services providers:https://www.fca.org.uk/brexit/temporary-permissions-regime-tpr
Information on unilateral equivalence decisions in the UK: https://www.gov.uk/government/publications/hm-treasury-equivalence-decisions-for-the-eea-states-9-november-2020/hm-treasury-equivalence-decisions-for-the-eea-states-9-november-2020
Information from the Liechtenstein Financial Market Authority: https://www.fma-li.li/de/internationales/europa/brexit-informationen-fur-finanzintermediare.html