Brexit & VAT: What’s Happening To Northern Ireland?
The UK train is leaving the EU station… but is Northern Ireland (“NI”) being left on the platform? Or is it along for the ride? This month’s Update takes on a MASSIVE question, not simply because of the inevitable impact the new rules will have, but also because there is quite a bit to talk about…
This Update is intended to be a quick summary of the main things we all have to look forward to. I’ve started off with a quick bit of general background, before focusing in on the VAT impact. As things develop, I strongly suspect I will be returning to Brexit in future Updates.
I finish up with a look at the “known unknowns”, to use a famous phrase of the unlamented Donald Rumsfeld, as things stand today. There are quite a few of these!
But anyway, let’s get our train-spotting journals ready and take a closer look at the traffic heading down the line…
Can You Give Me An Overview?
I’d be delighted to.
As we all know, Brexit means Brexit, but what does that mean? And more specifically, what does it mean for Northern Ireland?
First, it is important to understand that Northern Ireland has a “special status” under the Withdrawal Agreement.
The Withdrawal Agreement, for those of you so sick of politics that you just gave up following the “Never-Ending Story” (you are not alone…), is the “deal” agreed between Boris Johnson’s government and the EU in October 2019.
As part of this Agreement, a special “Northern Ireland Protocol” was agreed. This was designed to be a permanent part of the landscape, subject to a confirmatory vote in the NI Assembly within four years.
The Known Knowns
The Protocol is the source of this special status. It aims to achieve the following:
- NI remains part of the UK customs territory
- NI retains full access to the EU Single Market and Customs Union for goods
- There is to be no customs or similar infrastructure on the NI/ROI border
- Various other North-South cooperation matters (which are not really VAT-related) are protected
From a purely legal perspective, the Protocol seems to do a reasonable job of achieving these aims. However, a large amount of the detail on how the legal position is turned into a practical reality remains very unclear. I’ll return to the bigger “known unknowns” towards the end of the blog post.
As things stand, the UK government has passed an EU Withdrawal Act into law in January 2020. However, this Act does not address the specifics required under the Protocol.
These specifics have been left to UK and EU civil servants on a “Special Committee”, and for matters of principle, to a new “Joint Committee” of UK ministers and senior EU officials which is intended to thrash out the “hard parts” of the deal.
One important point is that most of the trading arrangements are to be under UK government management. That is, the UK government will be responsible for implementing the agreed rules on trade. However, the EU has the right to check on the UK’s implementation of the agreement, and to satisfy itself that the Single Market is not threatened.
You would have to worry that there are plenty of opportunities in all of this for people to fall out…
In August 2020, the UK government began to provide some clarity on its position.
For trade in goods, we now have the following assurances (at least from the UK side):
- NI businesses will have “unfettered access” to the rest of the UK market. That means that NI businesses will be able to sell their goods to customers in England, Scotland and Wales without difficulties. This is an important promise, but the precise way it will work is not yet clear. I return to this below in the Known Unknowns section
- NI businesses will be able to trade with the ROI and with the rest of the EU exactly as at present. That is, there will be no tariffs, no import or export declarations, no changes at all to the way in which trade with the rest of the EU is carried out. This provision has allowed the Border to remain entirely open and free of any infrastructure. This is legally agreed to be guaranteed even in the absence of a wider deal on the “future relationship” between the UK and the EU
- Trade with non-EU countries should be much the same as it is now, except that NI businesses will benefit from any reduced tariffs agreed by the UK with other countries as part of its “independent trade policy” after it has left the EU
However, there is one major downside arising from the Protocol.
Where goods are purchased from the rest of the UK and brought into NI, they will be subject to EU tariffs if they are deemed to be “at risk” of moving on to the EU. These tariffs will be collected by the UK government. Where tariffs are not, ultimately, due, the UK government will refund the tariffs levied to the business in question. We still don’t know exactly how this refund will happen. And we also don’t know what is meant by “at risk”.
The Protocol states that goods for processing will be deemed to be “at risk” (if you’re very keen, see Article 5), and that seems likely to cover quite a lot of the inward trade in goods.
Unless the “at risk” definition is agreed on a very narrow basis, this new set-up is therefore likely to be a big issue for very many businesses in NI.
To be fair to the UK government, it has announced a new “Trader Support Service” (“TSS”) which is due to be operational from early September. The TSS is free of charge and is designed to handle all of the potentially messy and complicated customs issues digitally. Exactly how it operates remains to be seen, of course!
Any business wishing to join the TSS will need an EORI number. This is not difficult to achieve, and I will be happy to help anyone looking to do it – just give me a call or send me an email.
Nevertheless, there are several big questions outstanding. I come back to some of these in the Known Unknowns section below.
What About VAT?
The special status I mentioned above is also (unsurprisingly) relevant for VAT purposes.
The Protocol sets out the following:
- For supplies of goods, NI will need to follow the rules of the EU VAT system. This means that the existing rules for trade in goods (including, presumably, simplifications such as call-off stock, though this will need to be confirmed) will continue after the end of 2020
- Future changes to EU VAT rules on goods will have to be implemented in NI
- HMRC will presumably need to have a special team dedicated to ensuring EU VAT rules are properly applied here – but we await details of how they will be handling this
- NI can apply reduced rates, zero rates and exemptions which apply in the ROI, but not necessarily in the rest of the UK (and vice versa). The palpable public excitement over the cut in VAT on women’s sanitary products from 5% to 0% is therefore justified, as this can apply in NI (because there is a similar provision in the ROI). However, future cuts which apply in GB may not be applicable here… Boris isn’t saying much about that part for now, however…
However, very importantly, NI will not be part of the EU VAT system for supplies of services.
This has implications for:
- The place of supply of services – in other words, which government is entitled to collect the VAT on a supply. Many services have different outcomes where the customer is based in the EU or in a non-EU country. After 1 January 2021, the EU countries will be regarded as “third countries” for UK suppliers of services
- Reclaiming VAT on services purchased in other EU states
- Businesses in NI which are supplying or purchasing services as well as goods (so most businesses…) will now have to grapple with two VAT systems. On “day one”, this is (hopefully!) not going to be a huge problem for most businesses, but as time passes, it is likely that the two systems will increasingly diverge. And for services, day one will bring changes, which are discussed in section 5 below
- Related to the position above, where businesses are making supplies which might amount to either goods or services (this can apply to certain construction-type works), it will be “interesting” to see whether this creates any additional issues. On the face of it, it should hopefully not be that different from before for projects taking place in NI. Whether that applies to NI businesses carrying out works in other EU states is another matter…
To return to the train analogy, the UK train is leaving the EU station – but only slowly. NI is in the very strange position of being left on the platform for goods, but on board the train for services. If the train doesn’t move much, this bizarre scenario might not be too problematic. If, however, the train speeds off, it is difficult to see how problems can be avoided.
What is more, this split is a bit of a curious outcome: cross-border trade in goods amounts to approximately £3.4 billion per annum, but cross-border trade in services isn’t too far behind at ca. £3.07 billion per annum.
To be fair, it should of course be noted that trade in goods tends to be much more problematic for customs purposes, and as a practical way out of the mess they had managed to get themselves into, perhaps it wasn’t the silliest plan… I’ll leave it to readers to draw their own conclusions.
Nevertheless, it seems very unlikely that either the UK or the EU have the desire or indeed the capacity to revisit the Protocol at this point. For that reason, the legal position for VAT position is probably that for goods purposes, we are under EU rules, and for services purposes, we are under UK rules, and that this will continue for the foreseeable future.
The EU has now published its views on the legal position for VAT for both goods and services, and the UK’s position does not – at this point in time – seem to be hugely different. I’ve had a look at each in turn in the next two sections.
We are still, however, left with some big questions here as well. I’ve addressed them too in the Known Unknowns section below.
What Happens To VAT On Supplies Of Goods?
By the looks of things, the short answer to this is “not that much” if you’re selling to or buying from the EU. If you’re buying from GB, the answer looks like “quite a bit”.
The summary of how goods will be treated can be seen in the following table:
||Member State of Arrival
||Member State of Dispatch
|Rest of World
||Rest of World
What does this add up to?
I intend looking into the EU rules on movements of goods in greater detail in future. However, I have summarised the key points below.
For NI businesses trading with the ROI and with the rest of the EU, the intention on all sides is that nothing substantive will change.
- EC Acquisitions rules will still apply, including zero-rating, etc
- EC Sales Lists will still be needed
- Intrastat returns will still be needed
The big changes will be on movements into NI from GB, which will for VAT purposes now amount to an import. This has major impacts from a customs perspective, but for VAT it means that the “exporter” in GB should be able to zero-rate the supply, while HMRC collect “import VAT” on it. In practice, it is doubtful how much of an issue this will be in cashflow terms (see below under “a bit of good news”).
In the EU’s view, movements of goods from NI to GB will amount to an export, but the UK’s position seems to be a bit more nuanced. They have promised “unfettered access”, as noted above, but how that is realised is not yet certain. I discuss this in section 6 below.
The new TSS should, in principle, assist in managing the processes involved, but for now it is difficult to advise exactly what is going to happen to trade in goods over the Irish Sea. We don’t know yet.
A Bit Of Good News
One important point which we do know is that HMRC have confirmed that import VAT will be subject to postponed accounting. What that means in practice is that import VAT will be paid and reclaimed on the VAT return, rather than paid upfront, and reclaimed later, as at present.
This will have the effect of making imports much more like EC acquisitions from a VAT perspective, and will reduce a major worry on the cash-flow front.
I will be looking to keep people updated on this subject as it develops. If you do have any queries about goods and VAT after Brexit takes effect, please let me know.
What Happens To VAT On Supplies Of Services?
It has been agreed by both sides that NI is not going to be part of the EU for supplies of services – that is, it will be on the UK train as it leaves the station. To get a handle on this, it may be helpful to start with a quick summary of where we are now.
Before going any further, a quick reminder on the “place of supply”. The place of supply is a concept designed to decide which government is entitled to collect the VAT on a particular supply. As a result, it mainly comes into play in a cross-border situation.
VAT law has a “general rule” for place of supply, and a number of exceptions (for example, services relating to land have a place of supply where the land itself is situated). I don’t want to get bogged down in the minutiae here, and intend revisiting the subject of place of supply at some point in future.
For now, it is sufficient to understand what the purpose of the place of supply rules is, and that it is split into a general rule and a number of exceptions. Some of the exceptions require registration in the EU member state of the customer. This requirement in turn has given rise to certain simplifications, e.g.: for electronically-supplied services (“ESS”), as discussed below.
The “general rule” for services applies to the bulk of supplies being made, and is itself split into two parts:
- Supplies made business to business (“B2B”): the place of supply is where the customer belongs
- Supplies made business to consumer (“B2C”): the place of supply is where the supplier belongs
For the vast bulk of B2B services, both parties are VAT-registered. This tends to make it easy: the “reverse charge” kicks in. The reverse charge makes VAT the customer’s problem. The supplier basically zero-rates its supply, and the customer charges itself VAT (and reclaims it, to the extent it is allowed to).
A quick example of how this works is as follows:
WirRaten GmbH is a German provider of high-quality professional services. In August 2020, it agrees to sell £100,000 worth of these services to SmartCo Ltd, which is an accounting firm based in Belfast. Both companies are registered for VAT in their respective countries.
This is a B2B supply of services subject to the general rule. That means the place of supply is where the customer belongs, that is, in the UK.
WirRaten GmbH issues an invoice to SmartCo Ltd, without charging VAT on the supply. SmartCo Ltd applies the “reverse charge” to the invoice, meaning that it includes the supply on its UK VAT return. SmartCo Ltd charges itself 20% VAT, and reclaims that VAT on the same return. The effect is therefore nil.
If this transaction takes place in August 2021, it should lead to pretty much exactly the same outcome – although WirRaten GmbH shouldn’t have to include the sale on its EC Sales List (or German equivalent…)!
Note that if SmartCo Ltd could only recover, say, 40% of its input VAT, it would end up only reclaiming £8,000 of the £20,000 of VAT (i.e.: (£100,000 x 20%) x 40%). And HMRC would collect £12,000 on the transaction…
What this means is that for supplies of B2B general rule services, the new arrangements shouldn’t be particularly troublesome, because they will be very similar (in effect) to the existing situation.
That is definitely welcome news!
The question of what happens to B2C general rule supplies is a bit different.
As things stand, some B2C services fall under the general rule when they are supplied to customers in the EU, but have a special category of their own when supplied to customers outside the EU. These are usually called “intangible services”, which isn’t terribly helpful.
I’ve taken the following list from HMRC’s VAT Notice 741A, paragraph 12.2:
- transfers and assignments of copyright, patents, licences, trademarks and similar rights
- acceptance of any obligation to refrain from pursuing or exercising a business activity
- advertising services
- services of consultants, engineers, consultancy bureaux, lawyers, accountants, and other similar services – data processing and provision of information, other than any services relating to land
- banking, financial and insurance services
- the provision of access to, or transmission or distribution through, natural gas and electricity systems and heat or cooling networks and the provision of other directly linked services
- supply of staff
- letting on hire of goods other than means of transport
- emissions allowances
To be clear, at the present time, the above services have a place of supply where the customer belongs when the customer is outside the EU. This is to be expanded to “outside the UK and Isle of Man” after 1 January 2021.
To give a B2C example, again using professional services, this can be seen very clearly:
SmartCo Ltd is an accounting firm based in Belfast. In August 2020, it provides tax services for Herr Fischer, a German individual who lives in Munich, and agrees to charges him £2,000 plus VAT, as applicable.
While the UK is in the “transition period”, the B2C general rule applies to these services. That means that the place of supply is where the supplier belongs, that is, the UK.
So SmartCo Ltd must raise an invoice and charge VAT at 20% on its services, for a total bill of £2,400.
However, when the following year comes around, Herr Fischer looks likely to save £400 on his bill.
This is because the accounting services are no longer covered by the general rule. Now they fall under the “Other services provided to recipient belonging outside the UK” (currently this reads “outside the EC”).
These services state that the place of supply is where the recipient belongs, that is, Germany, and so they are outside the scope of UK VAT – but they don’t create an obligation to register for VAT in Germany.
This looks like a “win” for SmartCo Ltd, and of course, for Herr Fischer…
If, however, we take a business providing services which might amount to general rule services, both before and after the end of the transition period, the result is unchanged.
One case which was recently decided on this issue was the case of Gray and Farrar International LLP, a high-end matchmaking service. Apparently, matchmaking does not count as “consultancy”, and is therefore a general rule supply. To turn it into an example:
LoveCo Ltd is a dating agency based in Belfast. Herr Fischer uses LoveCo Ltd’s services in August 2020, and signs up to pay £2,000 plus VAT to meet the woman of his dreams. LoveCo Ltd issues an invoice and charges £400 of VAT for its services.
A year later, Herr Fischer has been introduced to lots of delightful mädchen, but is still looking for Frau Right. He signs up with LoveCo Ltd for another year’s services in August 2021.
This time, LoveCo Ltd check what the VAT position is with their accountants. As the accountants cleverly subscribe to these Updates, they know the answer: it’s a general rule service provided B2C, so charge UK VAT.
Poor Herr Fischer won’t save any money on his dating services after all. But LoveCo Ltd won’t have to do an awful lot differently after 1 January 2021, which will save them a lot of worry.
You will begin to understand how much fun can be had in defining services by now. Rather than spend forever talking about this in the current Update, I’m going to revisit it in future. And if you have any doubts, please just give me a call or drop me an email.
The Problem Areas
The above gives a flavour of what is likely to happen to most services after 1 January 2021. Some attention is required, but in general it is to be hoped that the change will not be disastrous.
However, there are some areas of concern. Leaving the EU VAT system for services creates tensions in three main areas:
- Electronically-supplied services (ESS) supplied B2C
ESS are the problem children of cross-border VAT, because the place of supply is where the consumer belongs, and EU rules require the supplier to account for VAT in that jurisdiction. The nature of ESS means that a huge number of countries can be covered, which is less likely for other B2C services (e.g.: land-related services, for example). This means that suppliers have to register for VAT in every country in which they make supplies of ESS on a B2C basis.
Note that this applies now, and is expected to apply after the end of the transition period.
What kinds of services are defined as ESS? The definition is very wide, and in general includes anything which is supplied to the consumer without direct human intervention. So, for example, an e-book purchased by clicking a link after making a payment online.
The EU provides the following list, but it is not by any means exhaustive:
- website hosting
- supply of software
- access to databases
- downloading apps or music
- online gaming
- distance teaching
To this should be added, as a minimum, supplies of videos, e-books and other similar items.
At present, the hassle of registering for VAT in every single EU country can be avoided by signing up to the “Union VAT Mini-One-Stop-Shop (“MOSS”)”. This allows a single registration with HMRC, which then arranges to distribute the VAT due to the relevant countries in question.
Up until the end of December 2020, the VAT MOSS will continue to be available for UK businesses making these supplies. After that date, it will not be, even though the obligation to account for EU VAT will still stand.
How can this be resolved? For many businesses, the most practical thing may be to join the “Non-Union” VAT MOSS, by registering for VAT in the ROI and then applying to join the Non-Union MOSS through the ROI tax authorities.
If you have any clients providing ESS, please don’t hesitate to get in touch to discuss.
- Services with a “use and enjoyment” provision
I do not propose to go into this in any great detail here.
The key point is that, at present, services which have a “place of supply” of the UK, but to some extent are “used and enjoyed” outside the EU, will have a place of supply which is outside the EU to that extent (and vice versa). Once the transition period ends, the test will be whether they are used and enjoyed outside the UK, rather than outside the EU.
Given that the net will be a good bit wider, this might catch a greater number of cases than the existing rules do.
Some of the services with a use and enjoyment provision are:
- the letting on hire of goods (including means of transport)
- electronically supplied services (B2B only)
- telecommunications services (B2B only)
- repairs to goods under an insurance claim (B2B only)
- radio and television broadcasting services
If you have any doubts on this point, please don’t hesitate to get in touch with me.
- Refunds of EU VAT on Services
At present, VAT incurred by a UK business in another EU member state can be reclaimed via the EU VAT Refund Scheme. This is operated by HMRC in the UK, and reclaims are submitted by UK taxpayers via the HMRC gateway.
After the transition period ends, the EU VAT Refund Scheme will no longer be available for UK taxpayers – with one important exception: VAT incurred on goods will still be eligible for relief under the EU VAT Refund Scheme.
How exactly this will work is unclear – it will be interesting to see, to say the least!
In practice, the rule seems to mean that NI businesses will need to split their reclaims between goods and services, and apply for refunds under two separate schemes.
There are many restrictions in the existing scheme on how much VAT can be reclaimed, and each member state has its own rules, many of which are not particularly intuitive.
The 13th Directive refund scheme, which will apply to NI businesses for services, is less user-friendly, though the VAT in question should be recoverable to the same extent (in most cases) as under the existing scheme.
I intend to revisit the refund schemes later on, but if you have any queries about reclaiming VAT incurred in other EU member states, please let me know.
As you will appreciate, this is only a quick survey of the issues involved here, and I intend to revisit some of the bigger points in future Updates.
I would add that, ironically, one of the areas we have a bit more clarity is the question of services, precisely because we know that NI will be outside the EU VAT system for these purposes with effect from 1 January 2021
What Are The Known Unknowns?
Donald Rumsfeld, one of the architects of the Iraq War, tends not to be very warmly remembered these days.
However, he did gift the world one of the best soundbites in history: the concepts of “known knowns”, “known unknowns”, and “unknown unknowns”.
I’m going to address some of the more obvious “known unknowns” under the Protocol in this section. As to the question of whether there are any “unknown unknowns” we should be thinking about, well, I don’t know.
But I suspect it is safe to assume there are some lurking about
As you will have picked up by now, the customs procedures for movements of goods across the Irish Sea are likely to be the biggest area of difficulty. I am only highlighting the key issues here, and would not describe myself as an expert in customs (at least, not yet!).
First of all, we need to know what the definition of goods “at risk” of entering the EU will be. As noted above in section 2, the Protocol explicitly states that any goods intended for processing will be deemed as being “at risk”, and therefore subject to EU tariffs.
To put this in a very simplified form, this seems to mean that any business buying, say, flour for processing into bread, will face tariffs. To the extent that the bread is then sold in the ROI, the tariffs will not be refundable. So, if the business sells half its bread in NI and half in the ROI, it will only get a refund of half the tariffs on the flour.
Clearly this is potentially a major issue for businesses selling from NI to the EU, but with GB suppliers. Supply chains may need to be examined. Some GB suppliers may decide to stop supplying NI customers simply because of the hassle. Others may just put their prices up, or make other additional demands from customers to share the commercial burden of any new restrictions.
We also don’t know how HMRC will arrange for refunds of tariffs in the example given above. And that is, in some ways, the tip of the iceberg.
Secondly, we need to know how the UK government intends to deal with goods being brought into NI from the EU and then sold on to GB customers. This does not really seem to have been addressed at all to date.
The UK has spoken about NI businesses’ “unique” position with full access to both the EU and UK markets. The phrase used is “unfettered access” to the UK. It may be that in the event of a free trade agreement, where tariffs are non-existent, the UK authorities are relatively relaxed about goods moving from any part of the EU to NI and then on to GB.
However, there is still the question of enforcement, and how the UK authorities will prevent smuggling or similar nefarious activities.
There is talk of giving “NI businesses” some kind of preferential status, thus allowing registered businesses to avoid some or most of the administrative hassle. Whether some NI businesses could be given some kind of “UK-only trusted trader” status is also not yet clear, though if something like that could be created, that would probably take a large chunk of businesses out of harm’s way.
Thirdly, and related to both of the above, there is the question of “rules of origin”. As I say, I would not describe myself as a customs expert, but the basic issue is easy enough to understand. Where do the goods being transported come from? If, for example, sugar from Australia is used to make products in GB, and those products are then shipped to NI, are those “UK-only” goods? Or do they have any non-UK elements for customs purposes? I don’t know the answer to that, and the two sides do not appear to have agreed on that point yet.
You don’t have to be a genius to work out that it may be important.
The answers to these (and plenty of other) questions will determine how big an impact the new rules have on trade in NI and which businesses are affected. They will also probably have a decisive impact on supply chains between GB, NI and the ROI
Questions Relating To VAT
Turning to VAT specifically, some of the major known unknowns are:
- Will the (often quite useful) simplifications for goods movements available to EU traders still apply in NI after 1 January 2021? In particular, matters such as triangulation and the rules for installed-and-assembled goods are subject to member state choice. Will HMRC continue to operate them? And if so, how will it do so?
- How will HMRC manage the imposition of new EU rules for goods in NI, but not the rest of the UK?
- What VAT administrative requirements will be demanded for sales of goods to GB?
- What VAT administrative requirements will be demanded for purchases of goods from GB?
- What evidence will be required to claim import VAT back under postponed accounting?
- How will mixed or combined supplies of goods and services by or to NI businesses be treated? Will there be some bizarre outcomes?
These questions begin to shade into the unknown unknowns. Inevitably, situations will arise which nobody has foreseen. This is especially likely given how rushed the agreement relating to the Protocol was, and how badly the negotiations currently seem to be going
Summary:What Are The Key Points I Need To Remember?
The UK train is leaving the EU station. NI is in the unique position of both being on the station platform and sitting (comfortably?) in a seat on the train.
Unquestionably, there is still an awful lot we do not know yet, even though these changes will be taking effect from 1 January 2021. The UK Government has ruled out any extension to the transition period, and the (theoretical) deadline has now passed when it could have requested one under the Withdrawal Agreement.
So it looks like we will be finding out a lot more in a relatively short space of time.
What, then, are the key points we need to bear in mind?
First and most importantly, it is not quite “abandon hope all ye who enter here”. However, there are definitely going to be some changes and some challenges.
Trade between NI and the EU should continue largely as it is now. This is facilitated by the fact that, for goods, NI is effectively staying within the EU VAT system.
Trade between NI and the rest of the world should also continue largely as it is now, though there are some questions about how free trade agreements will operate in certain circumstances.
Goods moving from NI to GB have been promised “unfettered access”. This sounds good and if it becomes a reality, it will be good. But some of the heftier known unknowns are hanging around this issue.
Goods moving from GB to NI will be the big losers from the Protocol. The UK government has admitted that there will be new administrative requirements and for some categories of goods, additional safety checks too. It has also admitted that tariffs will, at least in principle, apply to those goods “at risk” of being moved to the EU.
This makes signing up to the new Trader Support Service (TSS) a really good idea for any business which moves goods across the Irish Sea.
The Protocol’s rules on VAT mean that the trade in goods between NI and the EU will be very much as it is today. However, there is a large known unknown in this area – how will NI manage with two VAT systems in place? One for goods, and one for services?
As with so much of this, we will have to wait and see – which isn’t hugely comforting…
Hopefully this Update has been helpful, and should you wish to discuss any of the issues arising – or indeed anything else VAT-related – please don’t hesitate to contact me for a free, no obligation initial enquiry.
Ciaran McGee, MA (Oxon), ACA, CTA
Tel: 028 71 876 220