The Brexit process and steps needed to be taken for Scotland to become an independent country have been compared in a new report.
The Scottish Centre on European Relations (SCER) study compares the UK leaving the EU with a deal which includes an indefinite customs union, with Scotland leaving the UK and being in, or acceding to, the EU.
It considers nine key areas; Sovereignty, democracy, divorce (concerning the splitting of assets and liabilities), political divisions, future relationships, relationships with the EU, new laws and regulatory bodies, relationships with the rest of the world, and borders/economic impacts.
The report suggests there would be greater certainty for a future independent Scotland-UK relationship, due in part to the EU having agreed arrangements by that time with Britain over its relationship – assuming an independent Scotland would be a member of the EU.
It also indicates lessons could be learned from the Scottish independence referendum in 2014 and the EU vote in 2016 in relation to how the process is conducted, as well as learning from how UK-EU law is either adopted or changed through Brexit.
The question of a border between Scotland and England is raised in the report as potentially causing frictions, however it indicates this could be better understood when the UK’s relationship with the EU is made clear.
The report states the untangling and splitting of shared liabilities could prove more difficult than the UK’s split from the EU.
It said: “Shared assets and liabilities and how to split them up would probably be a much tougher negotiation issue in the case of independence than for Brexit – not least the question of North Sea oil and gas, debt, defence assets, the siting of Trident on the Clyde, pensions, reciprocal rights to access public services and so on.
“Some might, eventually, be resolved on a per capita split basis but the talks would be difficult. And the still debated issue of whether an independent Scotland would continue to use the pound – for which there is no comparison in the Brexit talks – would potentially intrude Brexit.”
Dr Kirsty Hughes, SCER director, said: “There are, unsurprisingly, similarities and differences between the Brexit process and a likely future independence process. But overall the two are more different than similar.
“This is not surprising given that the UK is a sovereign state (whether in or outside the EU) while Scotland today is not a state but would become one on independence.
“If an independent Scotland were in the European Union, there would be more clarity over its future position and over a chunk of its future relationship with the UK, than the UK has in terms of its future relationship with the EU.”
A spokesman for Constitutional Relations Secretary Michael Russell said: “The chaotic and broken Westminster system demonstrates more than ever why decisions about Scotland should be taken by people here and not Westminster.
“Scotland voted overwhelmingly to remain in the EU but is being ignored by the UK Government which is taking us ever closer to a catastrophic no-deal Brexit and out of the European single market, which is eight times the size of the UK alone.
“This paper makes clear the benefits for people in Scotland from being an independent member of the EU, such as extra foreign investment and escaping the huge Brexit uncertainty which the paper says is driving growth and investment down in the UK and plaguing its politics.
“It also says ‘the huge uncertainty that haunts the UK over its future relationship with the EU would not hang over accession talks for Scotland’ and draws attention to the fact that the Scottish Parliament has been ignored and overruled by the UK Government during the Brexit process.”
But Pamela Nash, chief executive of Scotland in Union, said: “This report spells out in black and white that an independent Scotland would lead to a border between our friends, family and neighbours in England.
“As well as the devastating impact of dividing people, this would have a catastrophic impact on our economy, with 60% of our trade with the rest of the UK.
“The Brexit negotiations have proved just how difficult it is to break up unions, and our relationship with the rest of the UK is far more entwined than with the EU, so the divorce talks would be lengthy and costly.
“Rather than dividing people and putting up barriers, the majority of people in Scotland know we are better off together with a successful future built on sharing prosperity.”