ABSTRACT

More interesting from the aviation point of view is the agreement on a future relationship between the EU27 and the UK which may cover specific regulatory issues. From a political standpoint, the least controversial post-Brexit solution would be a bespoke aviation agreement between the UK and the EU27. Political interests at the EU27 member state level may interfere with Brexit negotiations. Importantly, the European Council Brexit guidelines clarify that, after the UK leaves the EU, no agreement between the EU and the UK may apply to the territory of Gibraltar without an agreement between Spain and the UK. The UK-EU27 agreement will only work for aviation relations between the UK and EU27 member states and would only give UK airlines traffic rights in these relations. Finally, the UK-EU27 deal will not encompass EU-third party relations governed by EU comprehensive and horizontal agreements.