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If the £20bn is based on the £32.50s (for a "frontier" declaration) then I think that is a very fair assessment and Mr Redwood ought to wake up and smell the roses. Of course, overall, it's higher than £32.50 because 2 or 3 declarations will be involved in trading with the EU - import, export and typically Transit in the middle; it's just a question of who pays for them. Any new costs for ports and carriers will also be on-costed because of course money doesn't grow on trees.
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