UK Brexit: Could Cyprus inspire pro-EU Scotland?

By Laurence Peter
BBC News

  • Published
Villas in Kyrenia, northern Cyprus, 17 July 07Image source, AFP
Image caption,
Villas in Kyrenia, northern Cyprus: Land and property rights are a big political issue on the island

An experience from the opposite end of Europe might influence Scotland's bid to remain in the EU during the UK's Brexit negotiations.

Cyprus joined the EU in 2004. Yet the island's breakaway, Turkish-controlled north is not internationally recognised, and EU laws don't apply there.

The UK's sovereign military bases in Cyprus are also outside the EU and have a special status.

The EU showed flexibility for Cyprus. It might do the same for Scotland and Northern Ireland, where majorities voted Remain (62% and 55.8%, respectively).

Why is the Cyprus example special?

The EU managed to find a way to admit the Republic of Cyprus, even though Turkey occupied the north in 1974 and the authorities there created the Turkish Republic of Northern Cyprus (TRNC).

Cyprus adopted the euro as its currency in 2008, yet the north uses the Turkish lira. And the massive body of EU law - called the Acquis - does not extend to the occupied north.

A UN buffer zone - the Green Line - divides the island. But in recent years peace efforts have facilitated contacts between the Greek- and Turkish-Cypriot communities.

Free movement of people - as British voters well know - is a thorny issue in the EU. It is one of the EU's cherished "four freedoms", enabling workers to move easily to another EU country. But it is problematic because it sets no upper limit on immigration.

And it does not operate across the Green Line.

The other three EU single market freedoms are: free movement of capital, goods and services.

Image caption,
Barbed wire and sand-filled barrels mark the Green Line in the capital Nicosia

To control the movement of people and goods in Cyprus the EU adopted the Green Line Regulation. The Republic of Cyprus has to check the IDs of everyone crossing the Green Line, and check all goods entering the EU from the island's north.

Cyprus and the UK are not in the EU's Schengen passport-free zone, where border checks are generally minimal.

What is the Scotland connection?

Image source, AFP
Image caption,
Scotland's First Minister Nicola Sturgeon is determined to keep Scotland in the EU

The UK government says it will not trigger the two-year exit procedure - EU Article 50 - until next year.

But when the formal exit negotiations begin, "some lessons can be learnt" from Cyprus's experience, as parts of the island required new agreements with the EU, Cypriot centre-left MEP Costas Mavrides told the BBC.

Because of the size of Scotland's Remain vote, Scottish resistance to Brexit appears stronger than that in Northern Ireland.

But constitutionally neither nation can stop the UK - as a state - going ahead with Brexit.

The UK's constitutional wrangling over Brexit and its consequences looks likely to be complex and take years.

But if pressure for Scottish independence grows, the Cyprus model could help serve as a transitional arrangement, according to lawyer Nikos Skoutaris.

The EU Law lecturer at the University of East Anglia says in an analysis that Scotland and Northern Ireland might reach separate arrangements with the EU as "a tangible alternative to secession [from the UK]".

The UK might then become "almost a confederation, but it will still be one recognised state".

Isn't it 'Brexit means Brexit' for the whole UK?

That is the UK government's position - and EU politicians have also stressed that the formal negotiations will be with the UK. So, no "Brexit lite" for Scotland or Northern Ireland.

Under the Sewel Convention, the Scottish Parliament should be asked to give consent to any UK legislation that affects Scotland - and that would clearly be the case with Brexit.

But Scotland cannot veto Brexit. According to Charles Grant, director of the Centre for European Reform, "Scotland cannot delay Brexit - it can only pass resolutions.

"Westminster can overrule the Scots on this issue, it's a matter of sovereignty," he said.

The EU will negotiate Brexit only with the UK, because "traditionally EU institutions are strongly opposed to separatism, as a destabilising force in the EU," he told the BBC.

Image source, AFP
Image caption,
Spain does not want Scottish moves in the EU to inspire Catalan separatists

Spain, worried about the strong independence campaign in Catalonia, does not want Scotland to create a precedent in the EU.

Mr Grant is on an expert panel advising the Scottish government on EU relations, as is MEP Alyn Smith of the Scottish National Party (SNP).

Mr Smith insisted that "everything is on the table, all options are to be explored". "[EU] membership is one thing, status is another, involvement in EU programmes is another," he told the BBC.

While he admitted that Westminster could overrule Scotland on Brexit, he said he was "loath to talk about vetoes or delays".

"But there is recognition that Scotland is looking for something different - the Brussels people know there's a plurality of interests in the UK."

Are there other half-in, half-out options?

Yes - there are many different EU arrangements to accommodate national differences.

Image source, Getty Images
Image caption,
The Akrotiri airbase in Cyprus is British sovereign territory

As part of the Brexit process the UK will have to re-examine its sovereign bases in Cyprus.

The Cyprus government voiced concern about Brexit's impact on the 15,000 Cypriots living in the Sovereign Base Areas. They are EU citizens, living in British territory.

"Living in areas exempted from the EU, now their status is not very clear," Mr Mavrides said.

Mr Smith says Scotland's SNP government is looking at the status of territories contained in other EU member states. Among them: the Aland Islands (Finland), the Faroes (Denmark) and Guadeloupe (France).

But dealing with small overseas territories is one thing - Brexit quite another.

The only territory to have left the EU is Greenland, part of Denmark. Its exit, in 1985, came after three years of negotiations. A fishing dispute triggered it - and Greenland's population is just 57,000.

The reality is that no existing model matches the Brexit case, as the UK is one of Europe's biggest economies.