UK vs EU

People who voted Yes and then Leave (the Yellow Tribe, as I’ve described them in the past) often talk of the UK and the EU as if they were almost the same, and they’re thus often keen to postpone Indyref2 till Brexit is done and dusted. “Why leave one union just to join another?” as they like to say.

However, is this fair? To what extent are the two unions alike? I thought it’d be useful to compare them topic by topic:

UK EU
The Houses of Parliament consist of two chambers. In the House of Commons, 59 out of 650 MPs are representing Scotland (9%). It’s hard to calculate the equivalent for the House of Lords because they don’t represent constituencies, but the Scotsman put the number at 61 out of 760 (8%) in 2015. This should be seen against the fact that Scotland makes up slightly more than 8% of the population of the UK. The European Parliament consists of 571 members. As an independent country, Scotland would probably have 13 MEPs (like Denmark), rather than the current 6, because small countries are over-represented. That would mean that Scotland would have 1.7% of MEPs on a population share of 1%. In the European Council, Scotland would have equal representation with all other member states (1 out of 28), so the same as Malta, Denmark and Germany.
There isn’t a specific number of Scottish ministers in the UK government. At the moment there is only one (David Mundell), but even that isn’t guaranteed (for instance, the Secretary of State for Northern Ireland isn’t Irish). The European Commission consists of one commissioner from each member state, so Scotland would always have one.
Westminster is sovereign, so if they want to change Holyrood’s powers, they can do so without consulting Scotland, although in the past they have done so. For instance, abolishing Holyrood altogether would be entirely within their powers if they thought that would be a good idea. The powers of the EU are described in the Treaty of Lisbon, and it requires unanimity to change it. This means that Scotland as a member state would have to agree before handing over any more powers to Brussels. There is absolutely no way that the EU could get rid of Holyrood.
Using the Pound Sterling is obligatory. In theory, Scotland would be required to adopt the Euro, but in practice it would be easy not to fulfil the criteria and thus stay out indefinitely, like Poland and Sweden.
It would be politically difficult for Westminster to refuse a new Scottish independence referendum, but they would be entitled to do so. The EU allows any member state to leave using Article 50. As we’re finding out at the moment, this is not easy, but at least it’s a guaranteed right.
The UK has one single foreign policy, and Scotland is not allowed to have its own. EU member states have their own foreign policy, but they have lots of meetings to coordinate their efforts. The EU has a nascent foreign policy, too, but this is in addition to the member states’ own policies, not instead of them.
The UK hasn’t negotiated its own trade agreements for many years and will have to do this from scratch after Brexit. The EU has great trade agreements with most of the world, and these apply automatically to all member states.
Westminster raises most taxes in the UK and then sends block grants to the devolved administrations. Each member state raises its own taxes and pays a membership fee to the EU.
The military is a British institution, and it’s completely controlled by Westminster. NATO membership is very important to the UK. As an EU member state, Scotland would be responsible for its own military forces. EU countries cooperate a bit. NATO membership is not obligatory.
The Tories are talking about walking away from the European Declaration of Human Rights and the jurisdiction of the ECHR. EU countries have to sign up to the ECHR, and the European Declaration of Human Rights forms part of the EU treaties.
The UK has over the centuries invaded most countries of the World. The EU hasn’t invaded any countries at all.
The UK used to do its best to get rid of Welsh, Gaelic, Scots and the other indigenous languages of the British Isles. It seems to have been mainly European influence that has led to improved support for minority languages. Linguistic diversity is in the EU’s DNA. As a full member state, Scotland will be able to designate either Scots or Gaelic as a full working language of the EU with translation of all texts and interpretation of all speeches in the European Parliament.
All oil revenues go straight to Westminster. EU member states keep their own energy revenues, and the EU might help member states build energy infrastructure, such as pipelines between member states.
British citizenship completely replaced Scottish citizenship in 1707. EU citizenship is additional to citizenship of a member state.
Anthem: God Save the Queen. Anthem: Ode to Joy.

If I’ve forgotten anything, please leave a comment underneath, and I’ll add it.

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