These Regulations are made by the Secretary of State under section 51(1) and (4) of the Taxation (Cross-border Trade) Act 2018 (c. 22) and are in consequence of, or otherwise connected with, the withdrawal of the United Kingdom from the European Union (“EU”). The Regulations relate to an international dispute or other issue that arose whilst the United Kingdom was a member state of the EU. As a result, this is an EU Exit statutory instrument.