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Background

The social security agreement between all EU member states takes the form of EC Regulations which apply across all Member States and also extend by agreement to cover Norway, Iceland, Lichtenstein and Switzerland (referred to in this guidance note as EEA countries).

The UK does not apply these 2004 and 2009 provisions to third country nationals and their contribution positions need to be considered under the previous provisions. The rules are broadly similar.

Brexit

The UK negotiated a Withdrawal Agreement and left the EU on 31 January 2020 (referred to as ‘exit day’) with an 11-month implementation period up to 31 December 2020. While exit day was important in terms of being the date the UK ceased to be an EU member state, the majority of key domestic tax and social security changes associated with Brexit took effect from the end of the implementation period (specifically, 11pm (GMT) on 31 December 2020, referred to as ‘(implementation