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Our thanks to law firm Charles Russell Speechlys LLP for extracting the art market headlines from the trade deal known in full as ‘The EU-UK Trade and Cooperation Agreement’.

…Moving objects between the UK and EU

• No tariffs, quotas and export taxes at the UK-EU border

• New customs and regulatory checks at the border

• Arts Council England to issue UK export licences rather than the EU export licences it issued pre-2021

• Removal of EU export licence thresholds

• No change to the ‘Waverley criteria’ used to decide whether export licences are needed

• Movement of goods solely for restoration are not subject to customs duties

• The deal recommits the UK and the EU to CITES

• The UK’s Ivory Act 2018 remains in place

…Value Added Tax (VAT) and ARR


• UK collectors buying art, antiques and collectables from the EU are now liable for import VAT of 5%, payable at the point of entry

• Exports from the UK and the EU continue to be zero-rated, though import tax now exists between the UK and EU

• EU collectors buying art and antiques from the UK will incur import VAT at their local country’s rate: Denmark’s rate is the highest at 25%, with France the lowest at 5.5%

• ARR (Artist’s Resale Right) remains in place


• Temporary Admission will continue

• EU dealers will no longer sell to UK buyers under the VAT Margin scheme, meaning UK trade buyers will be required to account for UK VAT on imports at the reduced rate (ie 5%)

• Postponed VAT accounting has been introduced for shipments into the UK from the EU provided the importer is authorised.

Source: Charles Russell Speechlys LLP