BEERG Perspective - Business in Scotland – out...

Many global businesses have operations in Scotland. Of the top 500 firms in Scotland, 54 are US multinationals, and 53 come from the EU. For many of them, easy access to EU markets for Scottish product matters. Scotland rejected independence in a referendum 6 years ago. But in the UK’s EU referendum 2 years later, the Scots voted to remain in Europe, and by a more decisive margin than that by which English and Welsh voted to pull them out. Might this push Scotland towards the independence it rejected 6 years ago? Would it then be welcomed back by the EU? 

How likely is this to happen? And how soon? Urgent questions for those with interests  in Scotland as we approach 1 January 2021 – the day after the Scottish Hogmanay; and the real Brexit date, after which tariffs and other barriers to trade between the UK and EU look set to bite. 

Scottish Nationalism: a serious political force  

Long the romantic enthusiasm of a varied cast of poets and patriots, the ambition for Scottish independence has gradually transformed into a formidable political movement. That journey began in 1967 when a by-election sent Mrs Winnie Ewing, a leading lawyer, from industrial Hamilton to London as the first MP for the Scottish National Party (SNP). Today the ‘ScotNats’ are the preeminent force in Scottish politics and custodians of a strong, devolved administration that voters trust. 

In the Westminster General Election last December, Boris Johnson’s Conservatives may have won decisively elsewhere. But the results in Scottish constituencies were very different: the SNP won 48 of the 59 Scottish seats.  

In the devolved Parliament in Holyrood, Edinburgh, SNP Ministers have led the government since 2011; and despite election arrangements carefully framed in 1998 to exclude the possibility of SNP dominance.

A critical moment is imminent

Fresh elections for the Holyrood Parliament are just a few months away, in May 2021. The SNP leader, First Minister Nicola Sturgeon, has committed to including a demand for a new referendum (‘Indyref2’) on Scottish Independence as the centrepiece of her manifesto. The SNP’s opponents have never been weaker. 

Most commentators expect the Scottish Nationalists to be the largest party again. They may even manage to win a clear majority as they did in 2011. 

Their line on independence has also grown more sophisticated. This was necessary, as the credibility of a case based on North Sea Oil and the Norwegian model has weakened. They now look towards Ireland’s example of success within the EU, buying into what they call a ‘post-sovereignty’ stance, as articulated by Garrett Fitzgerald, the thoughtful Irish leader and Taoiseach in the 1980s:

“I have come to the paradoxical conclusion that it is in the process of merging sovereignty with other member states in the [EU] Community that Ireland has found the clearest ex post facto justification for its long struggle to achieve sovereign independence of the United Kingdom.”

Boris v Nicola

Right now, the two main personalities involved are Nicola Sturgeon and Boris Johnson. Johnson is under fire on several fronts, from management of coronavirus issues to his choice of this time to pick fights with the upper echelons of the civil service and above all the deep concerns in vital quarters – not least business – about how the withdrawal  negotiations are proceeding. Despite his election victory Just 10 months ago, he looks vulnerable.

Nicola Sturgeon is the longest serving party leader, not only in Scotland, but the UK. Scottish Labour have had 6 leaders in as many years and their current leader, the Corbynite Richard Leonard, is fighting for his survival; while the Scots Conservatives are on their third leader in three years, Douglas Ross, who doesn’t even sit in the Scottish Parliament but was the only person who wanted the job. 

She may not be much liked in England but, when it comes to the country she leads and after 6 years in office, Sturgeon has a positive rating of 50. Johnson has a rating of minus 50 among the Scots. She seems to have weathered the storm surrounding her predecessor and mentor, Alex Salmond, the man who established the SNP’s authority as a serious party of Government in Scotland. Despite being acquitted, allegations of sexual harassment have left him, too, with a negative rating of 50 in the opinion polls. This is comparable to Margaret Thatcher, who was widely hated in Scotland for reasons outlined below, and from whose legacy Johnson does suffer. 

This transformation in the status of the ScotNats would have been difficult to believe 40 or even 30 years ago. The Conservative (or ‘Unionist’) party won most Scottish seats for the first half of the 20^th Century; while Labour went on to dominate Scottish politics from 1959 to 2000. The chan has taken place during the lifetime of most of Scots alive today. 

How it happened takes some explaining. 

What makes the Scots different from other Brits?

Nationalism, of course, has long found a raucous Scottish voice on thirsty occasions like Hogmanay and Rugby Internationals. Yet to many people from other countries, and not a few of the English, little seems to distinguish the Scots from other Brits, apart from tartan, bagpipes, the impenetrable Glasgow accent, and an over-fondness for whisky and Tennents lager. A brief history may help.

Scotland has battled with the English on many occasions over the centuries, and often lost. Unlike Ireland, however, it was never really a subject nation (witness the efforts of Mel Gibson in Braveheart). Nor was it reduced to the status of a ‘principality’ (or province) of the kingdom of England, as Wales was as long ago as 1301. 

On the contrary, the United Kingdom began in 1603 when the Scottish King James VI also succeeded Elizabeth to the English throne. The Union Jack flag is named after him, James being Jacobus in Latin. For the next century, however, both countries remained separate realms.

Thus, the subsequent Union in 1707 of the English and Scottish Parliaments at Westminster was an agreement between two sovereign nations to form one country (albeit the Scots were under severe economic pressure to do the deal, after the disastrous failure of their Darien colonisation venture in Panama).

Three fundamental differences have survived the Union. Scotland has its own legal system; its own education arrangements; and its own established church (Calvinist presbyterian, where England has Henry VIII’s unique, episcopal variant of Protestantism).  The significance of these elements has been eroded by three or four centuries of Westminster legislation and more recently by the development of common policy thinking on schools and universities, as well as by the general spread of secularism. Yet most Scots still appreciate this unique legacy. 

Changes that followed the Second World War – “the people’s war” – seemed to strengthen the Union, reflecting a common agenda across the nations of Britain following Irish independence and in anticipation of the imminent loss of empire: the welfare state and strong public services; a National Health Service (NHS) free at the point of demand; universal, free education; nationalisation of some key sectors; along with Keynesian economics and National Insurance to provide pensions and counter the pre-war scourge of unemployment. Planned during the wartime coalition, this programme was enthusiastically delivered by the landmark Labour Government of 1945. 

It was both respected and retained by Conservative successors from Churchill to Macmillan and beyond. Lately, Covid-19 has re-envigorated enthusiasm right across Britain for the NHS. Public support for all the elements of this post-war settlement was just as widespread, and rarely challenged, at least until the 1970s.

In Scotland it still is: a belief in equal opportunity, social justice and democracy seem to be part of the national psyche. They can be traced back through the ‘Red Clydesiders’ in shipyards and engineering during the first half of the last century, the coal miner Keir Hardie’s founding of the Labour Party in the 1890s, the Scottish Enlightenment movement in the 18^th Century, and more fancifully, to the Scottish nobles’ Declaration of Arbroath in 1320 asserting that any monarch must enjoy wide support, at least among themselves. 

England pursues different priorities

From 1979, England began to take a different course. Margaret Thatcher’s Government with its neo-liberal, monetarist economic policies – like those of US President Reagan – breached that post-war settlement, and it hit Scotland hard. Privatisation and supply-side economics removed nearly a third of its manufacturing capacity and almost all the heavy industries – not only coal and steel, but much of the shipbuilding and engineering on which the Scots’ global reputation had been built. It may have been a necessary catharsis; but it was done to the Scots, not by them. In all her 13 years of UK election victories, less than one in three of Scotland’s voters ever supported Thatcher’s party. 

The Scottish experience began to seem more like that of a country unwillingly colonised by England, rather than the more equal partner it had been in creating a British Empire.

Throughout the Thatcher years, Labour in Opposition seemed incapable of successfully challenging her approach in Westminster; while at the same time Labour in Scottish local government may have begun taking for granted voters’ continuing support across the old industrial and mining belt. 

Meanwhile, the ScotNats flourished as they gained experience both in local government and – from 1999 – in the revived Scottish Parliament.  

Now and over the last 4 weary years, in another instance of apparent subjection against their wishes, a UK government for which the Scots again did not vote in the General Elections of 2015, 2017 and last December, is acrimoniously separating them from the EU, where they wanted to stay.     

Do the Scots really want to be an independent country?

A fractious Royal Commission on the Constitution was set up back in 1969 to consider devolution issues following the by-election victories of both the SNP’s Mrs Ewing and Gwynfor Evans for the Welsh nationalists (Plaid Cymru) a year earlier. Its report emerged in 1973. Eventually, in 1979, a referendum for a Scottish Assembly followed.

While the majority of Scots voted in favour, the turnout was too low to meet a second threshold, requiring the support of at least 40% of the Scottish electorate. Nearly 20 years were to pass before Tony Blair’s ‘New Labour’ government held another referendum in Scotland in 1997. That won 74% support for a devolved Scottish Parliament on a 60% turnout, leading to its establishment in 1999. 

The next watershed was the 2011 election of the SNP with an absolute majority in the Holyrood Parliament. They demanded, and David Cameron’s government conceded, the right to hold a new referendum in September 2014. The referendum question was, "Should Scotland be an independent country?" 

The holding of that vote was agreed by the Westminster Government, which also promised to be bound by the result, after a lengthy period in which opinion polls had shown a majority of Scots wanting to remain in the UK. Further but limited powers to raise income tax and borrow money had been granted in 2012 to the Scottish government in the hopes of further blunting the SNP’s appeal. However, shortly before polling day, one opinion poll gave independence a 2% lead, which shocked the UK government into promising yet further powers to the Holyrood government if they rejected full independence, while warning voters that 

The Chart shows how opinion among Scots has developed over the last 5 years.

Scotland’s access to Europe depended on Britain’s membership of the EU. In the end, the "No" side won with 2,001,926 (55%) voting against independence and 1,617,989 (45%) in favour. 

It suggests that, soon after the referendum, they were having second thoughts. But for the next four years the polls were not encouraging for the ScotNats.  ‘No’ soon outstripped ‘Yes’. The gap narrowed at the time of the last Holyrood election in May 2016, but it did not close. Even after the Brexit vote in June 2016 and throughout the following 3 years, as Theresa May sought unsuccessfully to sell a softer form of Brexit to her MPs, the majority of Scots polled were against independence. 

On the right side of the chart, however, we can see that a major change in attitudes has developed during the course of the last 2 years, growing more acute after Boris Johnson replaced Mrs May in July 2019 – and especially in the months since he fought last December’s UK general election on a hard ‘get Brexit done’ ticket.

This helps explain why, despite her previous reluctance to try again so soon after the previous failure, Nicola Sturgeon thinks the timing may be right for having another shot.

The lead of ‘yes’ over ‘no’ has never been greater at any time. 

Yet even now, support for separating from the UK is still not trending above 50%, and a steady 10-12% of Scots (not shown here) remain undecided.

What happens next?

Brexit and Covid-19 stories continue to dominate the media in both London and Edinburgh. Handling Covid is one of the issues that falls to the devolved administration, and so far Sturgeon has fared much better than Johnson. She quickly distanced herself and her party from an SNP MP who travelled maskless, both while waiting for a test result that proved positive and after; whereas Johnson not only stood by an aide with symptoms who travelled similar distances during the total lockdown but gave him 10 Downing Street as a platform from which to mount his unconvincing defence. 

Once the Brexit outcome becomes clearer later this month, the focus in Scotland will shift further towards manifestos for the May election there. Sturgeon’s proposals will have to be spelt out and her proposed arrangements for a Indyref2 examined and debated. Already Johnson is being pressed by the media over both his discouraging response to the idea of a second Scottish referendum and his unpopularity north of the border.

Some upcoming developments may favour the ScotNats

With the clock ticking towards midnight on the negotiations between the UK and the EU on their future relationship, it is a racing certainty that the UK will not obtain a trade deal that would keep intact the current freedom of movement for British goods, services and people across the 27 EU countries. There will be consequences, and many of them will come as a nasty surprise for British businesses, workers and customers. The quantity, quality and availability of various goods and services, as well as the price, may well be affected adversely, at least for some years to come. Jobs will be lost as businesses find it harder to satisfy European customers from Britain and shift more of their operations to EU countries accordingly.  

New UK trade agreements with other countries are not going to replace what is likely to be lost any time soon. The much-heralded deal with Japan for example, looks likelier to benefit the Japanese more than the Brits. The Westminster government may seek to lay blame for these developments on EU intransigence, but Scots will know that none of this would have been a problem, had their wishes been respected. 

Meantime, the UK Government has handed the SNP a weapon which they can use against it: the Internal Market Bill.  The Bill has received much attention across the world because it could contradict the UK/EU Withdrawal Agreement - and therefore break international law. It says UK ministers would have the power to "disapply" rules relating to the movement of goods, including rules that flow from the Northern Ireland protocol agreed less than a year ago with the EU. It also says ministers can provide financial assistance to any person or company, which could override state aid rules also set out in the Withdrawal Agreement. 

However, for the Scottish Government it poses a different threat. The Bill applies a rule at UK level that would effectively prevent the devolved governments from setting higher standards; rather it could incentivise them to lower their standards. At present and during the transition, regional or local regulations cannot undercut EU requirements. However, they can provide better protection or improved rights; ‘gold-plating’ as it is sometimes known. The new Bill’s requirement that “any goods, services and qualifications which can be sold or used in one part of the UK can also be in another part of the UK” would seem to rule this out. The Scottish government and others see this as a cynical ‘power grab’ by Westminster that undermines their devolved authority and could encourage a ‘race to the bottom’ on regulatory standards. 

Nicola Sturgeon would not be alone in anticipating more missteps from the Conservative government at Westminster in the months to come, nor in thinking that they will help her win Indyref2.  Scottish Tory leader Douglas Ross has complained that among his fellow Tories in Westminster ‘talk of defeatism and disinterest towards the future of the Union is rife’. As a result, ‘the case for separation is now being made more effectively in London than it ever could in Edinburgh.’ They are ‘doing the SNP’s work for them’. 

Yet Sturgeon has challenging hurdles to surmount, starting next May

No-one, however, should imagine that an easy journey to independence for Scotland lies ahead.  There are a lot of decisions to be made by a range of different players as we shall see, and some of these could easily knock the ScotNats’ independence project off the rails with possibly fatal consequences for their ambitions.  

For a start, the SNP must win re-election in May of next year. Right now and given the parlous state of her Conservative and Labour opponents in Scotland, that looks the easiest part: but, as Harold Wilson said, ‘a week is a long time in politics’; and voting is still more than 6 months away. 

If they are to make a convincing case for a second referendum, the ScotNats really need to win big in May, securing an absolute majority under a system stacked against them, which they’ve only managed once before. 

Assuming that the SNP can get at least that far, they then face at least 3 more challenging obstacles which must be negotiated to end up where they want to be, as an independent nation in the EU.

Making sure of ‘Indyref 2’ and on terms that could let the ScotNats win

First, Sturgeon needs to win the agreement of the Westminster Government to holding that second referendum. 

There is a problem here, as David Cameron, UK Premier at the time of the first Scottish ‘IndyRef’ in 2014, has pointed out. He now says   

“Boris Johnson should reject a second independence referendum if the SNP wins a Holyrood majority because the UK government allowed the nationalists to set the terms in 2014….[when they] ‘asked for a once in a generation, once in a lifetime referendum’.” 

For the moment, Johnson seems to be in agreement with Cameron on this point, although that might conceivably change, e.g. if the ‘Little Englanders’ and the ‘defeatist’ tendency among Tory MPs decide that losing Scotland is not a matter for any regrets.

More likely, the British government will argue that it is too soon to put the country through such a disruptive and divisive experience again, especially as there’s more than enough to do in making a success of Brexit as a united country. 

The counter-arguments, however, are also persuasive. Brexit has changed things fundamentally. When UK politicians called on the Scottish electorate to reject independence in 2014, they cast doubt on whether an independent Scotland could retain the advantages of EU membership it enjoyed through being in the UK. Using the votes of England and Wales in 2016 to force Brexit upon Scotland (and Northern Ireland) against the will of their people has turned that argument on its head. The Scots’ best hope of securing the advantages of EU membership now, is to leave the UK.  

As we have seen, in a joint statement in the run-up to 2014’s referendum, the main UK parties also promised yet further devolution of powers if Scotland voted ‘no’ to independence. That promise has only partly been kept: a 2016 Act gives the Scottish Parliament fuller control over income tax and some social security benefits and some other matters from rail franchising to onshore oil and gas and makes it more difficult for the UK to abolish their parliament without the agreement of the Scots. Meanwhile, and to the contrary, moves such as the Internal Market Bill seek instead to undermine existing devolved powers. 

Finally, the precedent that Cameron himself set when granting the 2014 vote may help the SNP to win Court challenges to secure a new referendum vote, should the SNP win the May election and the UK Government then try to resist holding one. 

Sturgeon, however, really needs more from Westminster if the ScotNats are to hope for victory in the referendum. She needs agreement both on the timing of the referendum and on the terms under which it will be held. She will surely want it within a year or two of a Holyrood victory next May. The UK Government, however, may believe that public opinion in Scotland will be more favourable for them if it is held much later, when adverse effects of Brexit and Covid-19 are behind them. They might perhaps offer to put a pledge to hold and be bound by a Scottish referendum in their manifesto for the next UK general election, due at the end 2025. This would postpone the referendum until 2026 at the earliest. 

As for the terms, the SNP will want the simple yes-no question, “should Scotland be an independent country”, as before. They will also aim to open the vote, as they did in 2014, to all people resident in Scotland; and especially to younger people, including both overseas students and lads and lassies as young as 16. They know that their strongest support lies among those aged under 41, while older voters generally favour the Union. And they will want again to exclude all Scots living south of the English border or in other countries, to whom the Union tends to mean more.

Sturgeon may also demand the UK government’s explicit commitment on two further points: first, to respect the result; and, second, to act subsequently as honour bound by it – an outcome which Johnson’s recent clash with the EU over the Brexit Withdrawal Agreement suggests cannot safely be assumed.

Securing a Free Trade Agreement with the UK

The second big challenge for Sturgeon as Scotland’s leader is to secure a good deal with the UK on the future relationship between them, especially on trade. She will surely want the same sort of deal that the UK had been seeking from the EU as it departs that union: mutual free trade but without the rigid obligations of a member country to respect rules, to make financial contributions and to be governed by the decision-making institutions of the UK, including its Supreme Court. 

If we needed proof that the current UK government will have no problem with the evident hypocrisy of rejecting outright a pitch from the Scottish Government for a free trade deal with no strings, comparable to the one Michael Gove and Lord David Frost have lately been seeking from the EU, the Internal Market Bill provides it. As we’ve seen, that gives the UK government powers to limit domestic legislation by Scotland and the other devolved governments in Wales and Northern Ireland that undo devolution previously granted and indeed go beyond the powers the EU wields over Member States.

Getting Scotland back into the EU as quickly as possible

Third, she needs to secure for an independent Scotland favourable terms from the EU itself, preferably securing an early free trade agreement in advance of successfully completing the admission process. 

There are several reasons why an early admission is unlikely. The problem is not that Scotland is too small. Its $180 billion economy is bigger than that of Hungary and 9 other EU Members. One difficulty is that the admission process takes time – typically 10 years. An association agreement leads to the EU Commission preparing an opinion on the country’s readiness to commence negotiations. If the opinion is favourable and the EU Council agrees, the Commission then starts a screening process involving a comparison of the applicant’s laws with those of the EU as well as an assessment of its `administrative capacity. Negotiations are opened and annual progress reports made to the Council. Eventually a treaty of accession is prepared and signed, which must then be ratified by every single Member State and the EU institutions.  

The big unknown here is how the EU would react to such an application. There is a suspicion of nationalism in mainland Europe, which flows from experience of Dictators whose embrace of aggressive nationalism resulted in the horrors of the Second World War and its Spanish progenitor. 

This extends to potential hostility on the part of some Member States whose governments have set their faces against similar movements within their own borders – notably Spain, contending with the Basques and, most recently, with the Catalunyan separatist movement both in the Courts and on the streets of Barcelona. 

On the other hand, Scotland could claim to be a unique case, setting no direct precedents for the Catalunyans or similar movements, on the grounds that they had been pulled out of the EU by the UK Government’s actions and were utilising the only available route open to their dispossessed citizens for reversing that decision. The signs are that many in Europe following or involved in the current negotiations between the UK and the EU are disturbed by the attitude of the team from the Westminster Government and their dismissive and seemingly unrealistic ambitions. They are shocked by the bad faith exemplified by the Internal Market Bill overturning elements of the Withdrawal Agreement – an error of judgment in the view of all previous UK Premiers still living, and one which simply reinforces dormant prejudices about ‘perfidious Albion’. 

This might just possibly increase sympathy for the Scots administration across the EU 27 and make them more receptive to a speedier approach, including perhaps a free trade agreement as part of the association agreement. 

However, doubts about Scotland’s viability separate from an England outside the EU are quite reasonable, and it would only take one Member State to question the stability of Scotland’s institutions and its economy, or to find fault over the extent to which the new country was observing the acquis Communautaire, to slow things down, possibly for years.

Scotland can’t run with the English hare and hunt with the EU hounds

The truth is that an independent Scotland is likely to find itself seriously conflicted. It will want to minimise the immediate damage to its economy that breaking with England will cause, while restoring the link to the EU and its 500 million potential customers.  Yet entry to EU must mean that, subject to any transitional arrangements, Scotland would not only have to apply EU rules (as it does now) and adopt the €uro in place of the £, but it would have to behave towards the remainder of the UK in the same way as other Member States: and that will almost certainly include putting up tariff walls and barriers to trade. These would inevitably damage Scotland more than any other country in the world.

‘It’s the economy, Stuart!’

England accounts for more than 60% of Scotland’s trade: the EU only 18%. Many business operations in Scotland are closely integrated with linked activities across the border, serving a common British and – at least for now – European customer base. The biggest obstacle to achieving independence has always been economic rather than constitutional. 

The SNP still has a lot of work to do in articulating how they see the future panning out. That means setting out their plans for Scotland from when the UK leaves Europe in a few months’ time and until a referendum which they may want to hold as early as 2022 but will more probably come some years later than that; as well as explaining how they see the future developing if the referendum says ‘yes’ to independence. Part of their problem in doing so is that, like many businesses, they still need to see what the rules between the UK and EU will be from 1 January before they can frame their plans properly. But they will have to spell out their proposals more fully both before the May elections and again before any Indyref 2 is held. They can expect these exercises to draw a barrage of arguments and evidence from the UK Government playing up the problems independence would cause, as Westminster fights to maintain the union of the kingdoms. The longer that a referendum is delayed after 1 January next year, of course, the greater may be the difficulty for Scottish enterprise in just holding on to the 18% of trade it currently carries out with the EU in the face of new barriers to trade.

The Scots are known as a ‘canny’ people. It is one thing to trust the SNP as being more competent than either Labour or the Conservatives for the purposes of running the devolved administration; it is quite another to go along with the ScotNats’ wish for a break with their much bigger neighbour. Perhaps, the Scottish voters may reason, the SNP Ministers are more diligent now because they believe it will help them to achieve their ultimate aim: independence; and perhaps the same voters will ultimately decide that it suits them better to keep the nationalists diligently on their toes in their devolved ante-room, rather than let them through the doors to the independence ballroom and risk seeing them tear the place apart. 

There is ample scope for the UK government to play this dilemma to their advantage. They can point to the damaging self-harm that must be suffered from putting tariffs and other barriers between a Scotland in the EU and an England on the outside. It would mean jeopardising the trading and business relationships where the great majority of Scotland’s interests lie, in order to maintain free access to EU countries where, despite Britain’s membership for over 40 years, Scotland does less than 20% of its trade. If that case is made well, and especially if it is made not by Boris Johnson, but by a credible successor unencumbered by his unpopularity north of the border, it will have real traction. 

What’s the takeaway for business from all this?

There is no early or easy escape from Brexit for business via their Scottish operations. Nor is there much chance of an independence referendum before second half of next year.

Expect the ScotNats’ Nicola Sturgeon to succeed in securing Westminster’s agreement to a referendum vote on Scottish independence, after winning the May elections at Edinburgh’s Holyrood Parliament. That agreement may not come as early as she would like, or even before 2025. Would she win a referendum? Right now her prospects look good.  But the result is not a foregone conclusion, as a glance back at the chart on the recent history of the opinion polls demonstrates.

Much depends on matters largely beyond Sturgeon’s control: the relative economic performance of Britain and Europe, both in emerging from Covid-19 and, above all, in dealing with the disruption and system-shock caused by Brexit and its handling. If Europe recovers well and the UK slips back towards recession, the conditions may continue to favour Scottish independence, in due course as an EU member. Sturgeon could then portray the yes-no options in the referendum as effectively a choice between ‘no’, and being permanently tied to a failed or failing state trapped in a kind of self-important, post-imperial reverie; or ‘yes’ and, after some pain in the short term, ultimately flourishing in a strong, successful and dynamic Europe fully engaged in today’s world. Either way, the outlook looks likely to be disruptive to many businesses operating in Scotland for some years ahead, especially multinationals reliant on smooth international trading arrangements.