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It would be very surprising if the EU did allow us practice rights across the EEA without there being any judicial oversight at EU/EFTA level of compliance with Directives 77/249 and 98/5 and other related issues.

For example, take a UK-qualified lawyer who wants to practise in Italy. If problems are encountered, an action could be brought before the national courts and the case eventually referred to the ECJ. By contrast, an Italian lawyer in the UK would have to rely solely on domestic courts to adjudicate the dispute and hope that Parliament has given proper effect to EU-derived rights in national law. Not exactly a level playing field.

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