1On 17 January 2017, at Lancaster House, Prime minister Theresa May set out the Brexit “red lines” the British government would rely on in the negotiations. They consisted in ruling out any possibility of the United Kingdom remaining in a customs union with the European Union and/or in the single market. What she referred to as a “clean Brexit”, actually was a hard Brexit. Even though she had campaigned to remain in the EU, she was determined to honour the 2016 referendum vote and kept repeating “Brexit means Brexit”.
2The logic of a “clean break” with the European customs union implied that Britain would become a third country and that the common European Union tariffs would apply to British goods coming into the EU. Leaving the single market would mean that goods, services, capital and citizens would cease to move freely between the United Kingdom and the remaining 27 member states. This would apply to movements across the Irish border, which happens to be the only land border with the rest of the European Union. Customs posts and vehicle checks between Ireland, a remaining European member, and Northern Ireland as part of the United Kingdom, would have to be enforced whether they be tax, customs, regulatory or sanitory checks.
- 1 When she met with Irish Taoiseach Enda Kenny on 31 January 2017 in Dublin, Theresa May declared: “t (...)
3However, Theresa May, on a number of occasions, repeated her commitment to protecting the Good Friday Agreement by opposing any kind of physical infrastructure at the Irish land border1. There is a self-evident contradiction between a hard Brexit and an open Irish border and any attempt to reconcile those two objectives has been considered by many analysts as “squaring the circle”.
4This paper is meant to explore how the Irish border issue became the major stumbling block in the Brexit negotiations which reached a deadlock with Theresa May’s fiercely contested deal on account of the backstop. The deadlock was eventually overcome by Boris Johnson’s revised withdrawal agreement and a new plan for the Irish border.
5Border checkpoints and customs controls first appeared shortly after the establishment of the Irish state in 1922. From the late 1960s through the three decades of the conflict between protestant unionists and catholic nationalists known as the Troubles, British military checkpoints were established along the line on the main border crossings in order to contain the violence. They were gradually removed in the wake of the 10 April 1998 Good Friday Agreement which put an end to the conflict and led to the creation of a soft border. Over the past twenty years the border has gradually become inconspicuous like many interstate borders in the European Union. There are no physical barriers, no border posts, no checks on anyone or any goods that make their way from one side to the other. The development of north-south cooperation has largely benefited both economies North and South.
- 2 In March 2019 the House of Commons Northern Ireland Affairs Committee identified 142 areas of acros (...)
6Nearly everyone in Ireland would agree that reintroducing checks along the Irish border would be pure nonsense. Traffic which has been flowing unimpeded for two decades would be considerably delayed with border checks likely to become choke points. They would tremendously damage the closely interconnected economies North and South of the island2 and could lead to an escalation of violence, due to the political background of the Northern province and the legacy of the thirty years’ conflict that opposed Republicans and Loyalists.
7The Irish border issue soon became the major sticking point in the negotiations between the British government and the European task force which expected Theresa May’s government to propose a solution that would keep the Irish border open and fluid, despite the geopolitical changes generated by Brexit.
8Theresa May triggered Article 50 on Wednesday 29 March 2017, nine months after the Brexit referendum. During the first phase of the Brexit negotiations under May’s government the gap widened between British and European/Irish positions. The British government initially claimed that the Irish border issue could be solved in the negotiations on the future trade relation between the UK and the EU. But the European negotiators and the Irish government wanted legally binding commitments to be included in the Withdrawal Agreement, ensuring that there would be no return to a hard border.
- 3 Joint report from the negotiators of the European Union and the United Kingdom Government on progre (...)
- 4 Ibid., par.50. “In the absence of agreed solutions, the United Kingdom will ensure that no new regu (...)
9As the December 2017 European Council loomed ahead, the issue became critical and the two sides had to try and bridge the gap between their positions. Both parties, which believed that it was of paramount importance to avoid the return of a hard border, reached an agreement which was published in the form of a Joint report. It indicated three possible options3. A soft border could be preserved through an overall UK-EU relationship, or the UK would propose specific solutions to address “the unique circumstances of the island of Ireland”. “In the absence of agreed solutions” the third option4 would consist in maintaining the United Kingdom in “full alignment with those rules of the Internal Market and the Customs Union which, now or in the future, support North-South cooperation, the all island economy and the protection of the 1998 Agreement”. This option which was to be later identified as the “backstop”. It was also agreed that the border question had to be included in the Withdrawal Agreement, rather than postponed to the future relationship negotiations. The two sides had agreed on the wording of the Joint Report, but there was no clear indication on what the proposed solution would mean in practice.
- 5 In the wake of the 2017 snap election which resulted in a hung Parliament and a Conservative minori (...)
10Initially, the backstop would have involved Northern Ireland alone remaining in the EU’s single market and customs union with “continuing regulatory alignment in customs and trade practices across the island of Ireland”. But the Democratic Unionist Party5 warned it would not accept a Brexit deal which separates Northern Ireland economically or politically from the rest of the United Kingdom. Its leader, Arlene Foster insisted that “Northern Ireland must leave the EU on the same terms as the rest of the UK” causing Theresa May to shift her position on the backstop. Even though she had, agreed in principle to the idea of a backstop for Northern Ireland, she strongly rejected the EU’s renewed proposal as a threat to the “constitutional integrity” of her country claiming that “no UK prime minister could agree to it”.
11In early 2018 the discussions continued with no end in sight. While Brussels insisted that there should be a formal commitment to absolutely protect the peace process and all the benefits of the Good Friday Agreement, London kept referring to specific customs arrangements relying on technological devices that would make the land border “as seamless and as frictionless as possible”.
12In early February 2018, Michel Barnier again proposed that, if a better solution than the one involving the whole UK was not found before the end of the transition period in December 2020, Northern Ireland alone would effectively remain in the EU economic space for as long as a better solution hadn’t been found but May quickly rejected the plan, saying it “threatens the UK constitutional integrity”.
13In May 2018 Theresa May put forward an alternative to customs posts along the Irish frontier called maximum facilitation or “max fac”. It involved the use of technology through electronic customs registration, screening techniques and even a decentralised digital currency that could be used on the peer-to-peer bitcoin network. This solution, involving futuristic technology to make the border frictionless, was rejected by the Europeans as unrealistic and the Jacques Delors institute jeered it down as “the fiction of the frictionless border”.
14In June 2018, Theresa May reiterated her demand for a backstop arrangement which would apply to the whole country and not just to Northern Ireland but in the face of fierce opposition from members of her cabinet, one month later, a new Brexit plan on the future relationship between the United Kingdom and the European Union was agreed at Chequers, the Prime Minister’s country house, which consisted in a free trade area for goods to maintain frictionless trade along with a common rulebook and a new facilitated customs arrangement. The proposal immediately rejected by the EU as unworkable and bound to undermine the single market.
- 6 On 11 March 2019 the Northern Ireland Affairs committee published its interim report entitled “Impl (...)
15In November 2018 the Prime minister eventually agreed, albeit reluctantly, to a temporary backstop whose terms and conditions, she insisted, would not play a part in a permanent deal with the EU. The plan however promised that a specific negotiating track would be established as part of the negotiations in order to examine existing and potential facilitative arrangements and technologies that could possibly replace the backstop, which had already been rejected by Brussels as unrealistic6.
- 7 The word “backstop” comes from the sport of cricket. It refers to a fielder positioned directly beh (...)
- 8 GOV.UK, Withdrawal Agreement and Political Declaration on the future relationship between the UK an (...)
16The Withdrawal Agreement reached between British and European negotiators on 14 November 2018, included a Protocol on Ireland and Northern Ireland with the so-called “backstop7” solution. The European and Irish authorities had insisted that the planned mechanism had to remain part of the treaty. Nevertheless Article 1 insisted that the mechanism was not meant to establish a permanent relationship between the Union and the United Kingdom8.
17The Irish backstop, which had been considered as a safety net or an insurance policy, was a temporary customs arrangement between the United Kingdom and the European Union which would create a single EU-UK customs territory. Its aim was to ensure that, whatever the circumstances, there would be no hard border between Ireland and Northern Ireland and that the rights enshrined in the Good Friday Agreement would be protected along with North-South cooperation, the single Electricity Market and the all-island economy.
18The backstop also meant that the European Union’s common external tariff (CET) would be applied at the United Kingdom’s external border, alongside the Union Customs Code (UCC) and the other provisions of the Common Commercial Policy that were required to enable the temporary customs arrangement to function. It would also provide for the continuation of the Common Travel Area and imply the elimination of tariffs, quotas, checks on rules of origin and customs processes on all UK-EU trade at the Irish border. There would be additional provisions for Northern Ireland including regulatory arrangements related to the single market on goods.
19The Withdrawal Agreement prevented the UK from leaving the backstop unilaterally. To do so, either side would have to go to a Joint Committee which could consult joint UK-Ireland institutions.
20The Withdrawal Agreement faced immediate hostility amid British MPs mainly on account of the backstop provision which became the focus of opposition to May’s Brexit deal. Many conservatives and advocates of a hard Brexit resented the fact that the backstop was open-ended, which meant that the United Kingdom might be « trapped » in an indefinite customs union membership and remain in close alignment with the European Union. This was precisely what they had persistently dismissed. The Democratic Unionist Party led by Arlene Foster joined up with the hard Brexiteers from the European Research Group (ERG) such as Jacob Rees-Mogg or David Davis to call for the backstop to be dropped immediately.
- 9 Legal Effect of the Protocol on Ireland and Northern Ireland, Attorney General’s Office, 5 December (...)
- 10 The Attorney General’s statement indicated: “We are indefinitely committed to it (the backstop) if (...)
21The backstop triggered even more controversy among Conservative MPs after the Attorney General’s legal advice was known. In a six-page document9, released on 5 December 2018, Geoffrey Cox declared that he could not support the agreement since he believed that the United Kingdom would be entrapped indefinitely in the backstop that is the customs union with the EU10. In the wake of such statement, a large number of conservative MPs pledged to vote against the government’s deal unless the backstop was removed. They claimed that the backstop could tie the UK to European rules indefinitely while the UK would have no say in them.
22The vote on the withdrawal Agreement in the Commons eventually took place on 15 January 2019 and was rejected by 230 votes - the largest defeat for a sitting government in history. The Commons rejected the Agreement again on 12 March 2019, on a vote of 391 to 242, and again a third time on 30 March 2019 by 344 votes to 286.
23It had taken nearly two years and a lot of wrangling for the negotiators to agree on a temporary solution that would never materialise. When she realised that the Withdrawal Agreement bill, which she had failed to pass through Parliament on three occasion, could not be submitted a fourth time, Theresa May offered her resignation on 7 June 2019. After she resigned, Boris Johnson was elected leader of the conservative party and appointed Prime minister on 24 July 2019.
- 11 There was an exception for the Political declaration which was not binding,
24With May’s deal being defeated three times, mainly on account of the backstop, it was evident that an alternative solution still had to be found to avoid a hard border on the island of Ireland. The new Prime minister, who had pledged to “get Brexit done”, was determined to wrench a new version that would be more palatable to the advocates of a hard Brexit within his party. Yet, Brussels had made it clear that the Withdrawal Agreement would not be reopened, and the backstop would have to remain as it was11. The talks between European and British negotiators had come to a standstill. However eager Johnson was to strike a deal with the Europeans, it was quite difficult to see where he was heading to.
- 12 Their discussion focused on the issue of customs and consent and the potential to strengthen bilate (...)
- 13 “Boris Johnson and Leo Varadkar say they “see pathway” to Brexit deal, The Guardian, 10 October 201 (...)
25The 10 October 2019 private meeting that took place, between the Prime Minister and Irish Taoiseach Leo Varadkar12 at Thornton Manor, in the north-west of England, was seen as the last ditch attempt to reach a compromise before the European summit, which was due on 17 and 18 October. It actually proved a turning point in the negotiations. In a joint statement, the two leaders declared that they had had a detailed and constructive discussion and that they could see “a pathway to a possible deal”13.
- 14 Article 2, Subsequent agreement, par. 1: The Union and the United Kingdom shall use their best ende (...)
- 15 EUR-Lex, Agreement on the withdrawal of the United Kingdom of Great-Britain and Northern Ireland fr (...)
- 16 op. cit., Article 2, par.1, Rights of individuals, The United kingdom shall ensure that no diminuti (...)
- 17 Article 4, Customs territory of the United Kingdom, Northern Ireland is part of the customs territo (...)
26The deal that had been agreed between Prime minister Theresa May and the EU was partially renegotiated by Johnson over the following days. While May’s protocol on Ireland and Northern Ireland insisted that the backstop solution was temporary and meant to be replaced by a subsequent agreement14, the new Protocol within the Withdrawal agreement would provide the ultimate solution. The “unique circumstances on the island of Ireland and the necessity to maintain North South cooperation, avoid a hard border and protect the 1998 Agreement in all its dimensions” are emphasised in the revised Protocol as they were in the original one (article 1, Objectives)15. The rights of individuals are enshrined in both Agreements which pledge to safeguard the rights of Irish citizens and the respect of the Good Friday Agreement as regards human rights and equality standards16. Among the major changes, Northern Ireland will leave the European customs union alongside the rest of the United Kingdom, at the beginning of 2021. It will therefore benefit from Britain’s independent trade policy and any trade deal struck by the British government, for instance with the United States, after the transition period (article 4, Customs territory of the United Kingdom, which replaces article 6 in the 2018 Withdrawal agreement17 ).
27In order to ensure that there will be no checks on the island of Ireland, Northern Ireland will remain aligned with the Single Market regulations in areas such as regulation of goods, agricultural production and environmental regulation as well as state aid and other areas of north-south cooperation (articles 8, 9, 10 and 11). It will therefore follow European rules on procedures and tariffs. Within this new framework the border will de facto be located between the two islands in the Irish sea -an option that had always been anathema to the Unionists.
- 18 Article 5, Customs, movements of goods: No customs duties shall be payable for a good brought into (...)
- 19 Negotiations between UK and EU started on 5 May 2020 in the prospect of a free trade deal which mig (...)
28The province will have to be managed as an entry point into the European single market. As a result, British goods will require checks when entering Northern Ireland and the checks will have to be carried out at Irish ports and airports. Because of Northern Ireland remaining aligned with European norms and tariffs, goods entering Northern Ireland will have to be sorted out according to their type of destination18. For that purpose, a joint committee will identify the criteria that will determine whether a good brought into Northern Ireland is meant to remain there or is “at risk” of being moved into the Union. Two kinds of tariffs will be applied accordingly : British tariffs for products entering the province from outside the EU, provided they do not enter the single market and European tariffs for products likely to be moved to the Republic of Ireland. The latter will have to comply with European norms, in order to stop low standard products that might jeopardise the integrity of the single market19.
- 20 Article 18, Democratic consent in Northern Ireland, Par 1, 2, 3, 4, 5.
- 21 Article 18, par.6, a) “[…] a majority of those members of the Legislative Assembly present and voti (...)
29As a result of unionist anger and scepticism towards a differentiated treatment of Northern Ireland, the Johnson government secured a ‘democratic consent’ mechanism as part of the revised terms of withdrawal agreed in October 2019. The mechanism allowed members of the Northern Ireland Assembly (MLAs) to decide before the end of the fourth year of the Protocol’s operation (2024) – and regularly thereafter – whether key provisions of the Protocol should continue to apply20. The choice of every four years was to ensure that unless MLAs (Members of the local Assembly) decided otherwise, each Assembly would hold a vote The revised deal stipulates that such an opt-out would be by majority vote21.
30The response to the arrangements provided by the revised Protocol has been mixed. The deal ensured no border infrastructure would be built in Ireland and therefore removed any associated security risks. However, it strengthened the bond between Northern Ireland and Great Britain. But the Irish sea border immediately triggered indignation from the Democratic Unionist Party which referred to the new border deal as the betrayal act. For the EU, the integrity of the single market is maintained and its commitment to Ireland is clearly underlined. However, the practical measures required by the protocol soon proved controversial.
- 22 According to Michael Gove, the “implementation of the protocol would not involve new customs infras (...)
31Rows over the implementation of the Protocol on Ireland and Northern Ireland have emerged over the first few months of 2020. The European task force has always called for a strict implementation of the provisions concerning checks at the Irish sea border while the Prime Minister has denied that there would be any. His attitude, which implied that he was not willing to uphold the agreement, which he had signed in January, caused a lot of frustration among Europeans. Despite the Prime Minister’s denial, on 11 February 2020, Michael Gove, the Cabinet Secretary, announced that there would be declarations on goods moving from Great Britain to NI to provide rigorous checks on agrifood and live animals22.
- 23 Article 12, par 2, Implementation, application, supervision and enforcement, “The United Kingdom sh (...)
- 24 Article 15 par. 2, Joint consultative working group, The working group shall be composed of represe (...)
32In May 2020 further tensions arose between Brussels and London over the role of the representatives of the Union in the joint consultative working group. The request by the Secretary General of the European External Action Service, Helga Schmidt, for a European office in Belfast was in compliance with article 2 par. 2 on Rights of individuals, article 12 par. 223 on Implementation, application, supervision and enforcement as well as article 15 par. 1 and 224, Joint consultative working group, which all refer to the presence and contribution of Union representatives to EU-UK customs work. However, Cabinet secretary Michael Gove’s answer to Helga Schmid was that there was “no need for a mini Embassy in Belfast”, thus closing down any kind of continued European presence.
33Not unlike his predecessor’s, Johnson’s deal received little support amongst Parliamentarians.
34Instead of attempting to rally a majority at Westminster, Johnson decided to call for new elections with the hope that a larger majority would put an end to his dependence on the DUP. His overwhelming victory at the 12 December general elections gave him a clear mandate to get his deal through Parliament. The Withdrawal bill easily passed through all the stages in the Commons and cleared the way to the UK’s official exit from the European Union on 31 January 2020.
- 25 Prime minister’s questions, Westminster Parliament, 9 September 2020.
- 26 “The Union and the United Kingdom shall, in full mutual respect and good faith, assist each other i (...)
- 27 According to Article 5, 2 of the Protocol: “Before the end of the transition period, the Joint Comm (...)
35On 9 September 2020, at the start of the eighth round of the post-Brexit talks on the future UK-EU trade relation, the United Kingdom government published draft legislation on how it intended to manage trade within its borders after the end of the transition year. The Internal market bill was described by the Prime Minister as a “legal safety net” to ensure “unfettered access” to the overall British market for Northern Ireland businesses and “to protect our country against extreme or irrational interpretations”25 of the Northern Ireland protocol in the Withdrawal Agreement signed in October 2019. Even though the Withdrawal Agreement very clearly stated that both the UK and the EU remain committed to the principle of ‘sincere cooperation’ and that neither party in the negotiations should adopt measures to undermine the International Agreement26,Part 5 of the bill, entitled “Northern Ireland Protocol”, is actually meant to bring unilateral changes to some of the provisions of the Protocol. It gives British Government ministers powers to decide on the Irish sea border arrangements27 in case the joint committee proves unable to reconcile the positions of the United Kingdom and the European Union.
- 28 After the Prime minister repeated that there was “no question of there being checks” on the movemen (...)
- 29 United Kingdom Internal Market Bill, Part 5, Northern Ireland Protocol, Unfettered access to UK int (...)
- 30 Ibid., s 42, Power to disapply or modify export declarations and other exit procedures (1): “A Mini (...)
36The question of whether customs checks were required for goods going from Northern Ireland into Great-Britain has proved very controversial28. In clause 41, the bill29 provides for « unfettered access to [the] UK internal market for Northern Ireland goods » and prohibits any additional checks on goods between Northern Ireland and Great Britain. Furthermore, clause 42 of the bill30 provides Ministers with the power to « disapply or modify » export declarations exit procedures, including those set out in the Protocol for goods moving from Northern Ireland to Great Britain. These two clauses clearly contradict article 6, 4 of the Protocol which indicates that goods moving from Northern Ireland to Great-Britain need to comply with “technical regulations, assessments, registrations, certificates, approvals or authorizations governed by provisions of Union law”.
- 31 Protocol on Ireland/Northern Ireland, article 10, State aid, par. 1,2.
- 32 Ibid., Annex 6, Procedures referred to in article 10 (2).
- 33 United Kingdom Internal Market Bill, Regulations about Article 10 of the Northern Ireland Protocol, (...)
- 34 Ibid., Northern Ireland Protocol, Regulations about Article 10 of the Northern Ireland Protocol s. (...)
37Rules on state subsidies have also been a contentious element in the negotiations between the EU and the UK which has repeatedly objected to the application of EU « State aid » rules to government subsidies. Under Article 10 on State aid the British authorities agreed to make EU State aid law applicable to measures or subsidies “which affect that trade between Northern Ireland and the Union which is subject to this Protocol. It clearly indicated that there would be a maximum overall annual level of support31 for the production and sale of agricultural products that would be determined by the Joint Committee32. Yet according to clause 43 of the bill, “the Secretary of State may by regulations make provision for the purposes of domestic law in connection with Article 10 of the Northern Ireland Protocol33 (State aid). It also clearly stipulates that Article 10 is not to be interpreted in accordance with case law of the European Court34. Clause 44 also states that the Secretary of State only may notify the European Commission for approval on state aid.
38As for clause 45, it clearly indicates that regulations under clauses 42 and 43 cannot be judged unlawful on the basis of incompatibility with international law, which clearly restricts or event prevents domestic judicial review, and can be referred to as an “ouster clause”.
- 35 Brandon Lewis admits the government plans to break international law, New Statesman, 9 September 20 (...)
- 36 In her response to the Irish Times at a news conference in the US Capitol, Nancy Pelosi declared: “ (...)
39The government’s move immediately caused widespread shock and infuriated protests on the part of leading figures both in Europe and in the UK. A mounting tory rebellion emerged in the Commons, which widened after Northern Ireland Secretary Brandon Lewis conceded that the bill would go against the Protocol in a “specific and limited way”, insisting that the changes would amount to « minor clarifications in extremely specific areas »35. After an emergency meeting European Commission vice-president Marcos Sefcovic stated that, if the bill were to be adopted, it would constitute an extremely serious violation of the Withdrawal Agreement and consequently demanded that the UK withdraw the contentious bill in the shortest time possible and in any case by the end of September. A number of observers pointed out that there were mechanisms and legal remedies to address violations of international law and the Commission stated that it was ready to take legal action against the UK if it violated the letter or the spirit of the Withdrawal Agreement. House of Representatives Speaker Nancy Pelosi joined in the protests and warned that a trade agreement between the United States and Britain would not happen if the Belfast/Good Friday Agreement was undermined36.
- 37 Prime Minister’s statement on protecting the Union, Westminster Parliament, 14 September 2020, http (...)
40The European Union rejected Johnson’s argument that the bill was meant to protect the Good Friday/Belfast Agreement but declared that it was doing the opposite by jeopardising the objectives and achievements of the Agreement. Within a week’s time the Prime Minister caved in to pressure from his own party and agreed to table a government amendment to the bill, similar to the one proposed by Conservative MP Robert Neill, whereby the government would have to win a vote in the House of Commons before using the contentious provisions in the Internal Market Bill. He also added that what he called “an insurance policy” would not be invoked if a trade agreement was reached with the EU37. Nevertheless, his promises were not sufficient to placate the concerns of those who had voiced their strong objections at Westminster and at European level.
41The Irish border has proved one of the thorniest questions in the Brexit process. On 17 October 2019 Boris Johnson claimed that he had struck a “great new deal”, the perfect agreement that would avoid a land border and ensure unfettered access for Northern Irish and British firms across the Irish sea. The focus on “getting Brexit done” at all costs as opposed to the concern for quality and sustainability of the deal, may leave Northern Ireland in a complicated situation.
42The implementation of the revised protocol has proved contentious because of Northern Ireland’s hybrid status and Britain declaring its intention to diverge from EU rules. The Europeans have insisted on customs checks on goods across the Irish sea to make sure the right tariffs will be applied and the risk of smuggling across the Irish land border reduced. Thousands of customs officers could be needed for all the paperwork that border checks will require at Irish ports such as Larne or Warrenpoint.
- 38 It has also deeply damaged the relations between the United Kingdom and the Republic of Ireland, wh (...)
43The publication of the internal market bill has seriously damaged mutual trust and confidence between UK and EU representatives38. The European Union has persistently repeated that a trade deal can only be agreed if the withdrawal agreement, including the Northern Ireland Protocol, is fully operational. While hardly any progress has been made in the trade negotiations, with very significant divergences on fisheries, the level playing field and state aid along with the role of the European Court of Justice and commitments to human rights under the European convention, a no deal outcome looks even more likely.
44Against such a background of hostility and mistrust, aggravated by the covid crisis, there is no doubt that the British exit from the EU will seriously impact the future of the Northern Ireland province. Given the hard-line stance of the British negotiators and their pledge to diverge from EU rules, it can be assumed that Brexit will undoubtedly complicate the implementation of the three strands of the Agreement which are interconnected and interdependent. It will generate further tensions and disputes, not to mention the damaging impact on the two economies North and South.
45Amidst all these uncertainties, talk about a united Ireland has re-emerged. According to Professor Colin Harvey39 from Queen’s University Belfast, “the issue has now gone from the margins to the mainstream as a result of Brexit”. Although a united Ireland is unlikely to happen in the short term, the constitutional future of Northern Ireland will probably dominate the political agenda over the decade.