29 February 2016

Would Brexit end Britain? A tale of two unions

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As Nicola Sturgeon uses a speech in London to set out her case for why the UK should vote to stay in the EU, Sunder Katwala asks what the implications of the EU referendum might be for Scotland and its relationship with the rest of the UK.

Photo: Chris Watt
Photo: Chris Watt

For over half a century, this has been a debate about Britain and Europe.  Yet British identity has changed in a changing Britain – and neither side of the EU debate has kept up.

The ‘Stronger In’ campaign to remain in the EU launched in red, white and blue, keen to show it is making a patriotic British case. It will need to show it can speak to Wales, Scotland and England too. UKIP’s name captures that is a pro-Union British party, though Euroscepticism appeals most strongly to those who feel English rather than British. That gives the ‘Leave’ campaign a challenge to show it can win votes across the United Kingdom – with a particular headache over how to persuade Scotland and the consequences if it failed to do so but did win the argument elsewhere.

Strikingly, Scotland was more Eurosceptic than the rest of Britain in 1975, when 42% of Scots voted to leave, compared to 37% in Wales and just 31% in England. Northern Ireland was most Eurosceptic of all, staying in by just 48% to 52%.


Today, Scotland is consistently a bit more pro-European than England – which creates the possibility that the different UK nations might have opposing majorities for ‘Remain’ or for ‘Leave’. The SNP argues that a Brexit vote should only be valid with an out-and-out majority in each of the four UK nations, though the referendum rules will mean that a simple UK-wide majority wins.  However, clashing majorities in Scotland and the rest of Britain would be likely to trigger a new referendum on independence, a central question in Scottish politics.
Scottish pro-EU votes could, in theory, overturn a Brexit majority elsewhere in the UK if the vote was on a knife-edge. Relative population sizes means only an English ‘Remain’ vote of around 49% could be pushed over the line by pluralities elsewhere. With a Scottish electorate of 4 million, a much wider margin of Scots voting to stay in the EU could find their votes outweighed by Welsh and English votes to Leave. In that event, the EU referendum could well prove decisive for two Unions rather than one.

There is little evidence that many English, Welsh or Northern Irish voters would change their minds on the EU to keep the UK together. Even if majorities across the UK had hoped for a Scottish ‘No’ in the final weeks of the 2014 independence referendum, this is unlikely to have mass public salience during the argument about Europe. It could well be a considerably greater dilemma for Scottish Eurosceptics who support the Union.

The ‘Leave’ campaign should give a high priority to trying to win in Scotland as well as England. But this requires a significant cultural shift – and new messengers. Scottish attitudes towards the EU are only mildly more positive – but the reputation of UKIP is considerably more toxic in Scotland than elsewhere. The party secured just 1.6% of the General Election vote in Scotland compared to 14% in England and Wales. Research for our post-election report The politics of immigration found that two-thirds of Scots consider UKIP to be a ‘dangerous and divisive party’ which ‘risks bringing prejudice into debates about immigration’. This makes the cultural challenge for ‘Leave’ of finding a different tone and different messengers especially pressing in Scotland.

If ‘Leave’ won, but lost Scotland, some on the ‘Out’ side would find a result that was not quite the ‘full Brexit’. Speaking at a British Future event, UKIP MP Douglas Carswell took an agnostic view of the future of the UK: “If I was in Scotland, I don’t know how I would vote on the UK,” he said, voicing an instinctive sympathy that might lie with pro-independence Scots. “Do we think it would be better if Ireland were still run from Whitehall? I’m a localist. But I’m not a Scot,” he said. “Where I can be much more certain of my views is in the need to leave the EU,” he added, suggesting the break-up of the UK would be a price worth paying for departure from the EU.

The aftermath
In a second independence referendum, caused by Scotland being outvoted on the EU, it is widely assumed that the pro-independence side would start as favourites. The outcome, however, would not be certain. This scenario would create several new questions in a fresh independence referendum: as to how Scotland could now seek to rejoin the EU, or remain a member if it could become independent before the UK’s exit was formalised; about what economic relationships an independent Scotland inside the EU would have with a UK that was leaving, and whether the currency of an independent Scotland in this scenario would be the pound, the Euro or an independent Scottish currency; and about whether EU free movement and the absence of immigration controls within Britain were compatible.

There would be pressure to hold a Scottish vote relatively quickly, since it would be more difficult to negotiate the terms of exit if there was considerable uncertainty about whether Scotland would be in either the UK or the EU within a year or two.

Negotiating a British exit from the European Union is a complex task – and a British government could find itself trying to conduct departure talks from the EU and negotiations to dissolve the UK with an independent Scotland simultaneously. If Scotland had voted for the EU, and for independence, then the Scottish government would be establishing the terms of independence while also dealing with the unique situation of seeking to secure EU membership as a current part of a departing member state.

If the EU vote does lead to the dissolution of two Unions, then the British and Scottish governments would probably face the most complex diplomatic challenge of any modern democratic government – making it harder still to confidently define the consequences of a vote to leave the EU.

This article first appeared in ‘How (not) to talk about Europe’ by British Future, published in January 2016.

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