As a Berliner travelling from London to Edinburgh and strolling along the streets of the old and new towns one feels unexpectedly at home in a way one never feels at home in London. Why is this? The realisation comes suddenly. It is the dominance of tenements.

Instead of living next to each other – a tremendous waste of land in Berlin eyes – the inhabitants of Edinburgh live mostly one on top of the other like people in mainland European cities do.

According to Robert Hodgart, an urban geographer and retired lecturer at the University of Edinburgh, this phenomenon is a “visibly conspicuous facet of Scotland’s distinctiveness, which gives it a stronger affinity with continental Europe”.

It’s not only the architecture that contributes to the impression that crossing the invisible border from England to Scotland is like crossing the border between two separate states – one on an island, the other on the continent.

The federal states in Germany have their own governments and parliaments and even their own school systems like Scotland. And some, such as Bavaria or Saxony, which call themselves “Freistaat”, are highly aware of their own cultural identity highlighted by dialect, dishes and customs.

But still no federal state in Germany prints its own money like the Scottish do or has its own “national museum” with the Declaration of Arbroath taking up a whole wall. The Germans having formed a common nation only in 1871 are not struggling against it while the Scottish who joined the Union in 1707 still do.

And after the EU referendum the union is called into question again. The majority of Scottish people voted for remain. Scots seem to feel at least as close to the EU as they feel to the UK. Do they have to take a decision now to which side they belong?

Part of the reason the referendum for independence launched in 2014 by the SNP failed was because a lot of Scots were convinced they would enjoy the benefits from the UK and the EU by voting no. However, that argument ceased on 23 June.

Barbara Flynn, a community developer who lives with her Spanish husband in Glasgow, says she voted for Scottish independence even though there was a common fear at the time that Scotland would have to leave the EU after becoming independent. In light of the EU referendum result, she says, many people regret their decision to vote no. “They say: I wish I had voted yes two years ago,” she says.



Both Diane Stewart and Kallum Corke, who are in their 20s and work in Edinburgh also voted for “Better together” two years ago. The Brexit vote felt like a “punch in the face”. They hope the Scottish government can persuade Downing Street “to leave us in”.

Flynn is more determined. “The government should now push another independence referendum,” she says.

I met all of them at the end of October attending a conference in Edinburgh on the issue: Scotland after Brexit.

Can Scotland be a member of Brexit-Britain and the EU at the same time or have the Scots to leave the Union? That is the question and there is no evident answer.

Dominic Hinde, a journalist based in Edinburgh who lived and worked also in Berlin, Stockholm and the US, is convinced. “The option for Scotland is now to become independent or to stay in the UK and leave the EU and the single market.”



He is also clear that the second option is the more probable at the moment: “Although the majority of the Scottish support the EU they are reluctant about the idea of independence. And a failure of a second referendum would kill the idea of Scottish independence for a long time.”

Immediately after the Brexit vote, the first minister of the Scoland, Nicola Sturgeon, said a second Scottish independence vote was highly likely.

Five months later she does not sound so resolute.

Although the government published a new independence bill in October, Fiona Hyslop, the cabinet secretary for culture, tourism and external affairs, is reluctant about a second independence referendum happening so soon. “It’s not our starting point,” she says.

Tenements in Edinburgh. Photograph: Murdo Macleod/The Guardian

“The first is trying to persuade the UK as a whole to take a position as close to the EU as possible. From our perspective that means remaining a member of the single market as a whole. If that’s not possible we will be setting out in a few weeks time the mechanism by which Scotland could have a different model within the United Kingdom where we might retain membership of the single market. If these two are not possible then independence is not off the table.”

Another independence referendum is the least desired option and looking at recent polls it is easy to tell why: a new poll published by YouGov this week finds that the support for a yes campaign was dwindling.

Ask Hyslop how probable a special deal for Scotland is and she appears optimistic. “A flexible Brexit is possible,” she says and refers to the case of Germany after 1990. “We have seen how flexible the EU was particularly to East Germany in the view of the reunification and the challenges there. So we know the EU can be flexible if there is the political will to do that.”

Does Hyslop, who was recently in London to meet the ambassadors of the 27 remaining EU members, see the political will? “Well, we will not only be engaging with the EU 27 but also with the institutions in Brussels. As we understood there is a great deal of support and sympathy for the position Scotland finds itself in,” Hyslop says.

But there is still the British government which has to concede special rights to Scotland. “There has been a lot of activity between the UK, Scottish and other devolved administrations”, the Scottish government states in its newsletter on Friday.

The conference in Edinburgh in October heard from academics and politicians from six northern European countries including the Faroe Islands and Greenland, who told of their experiences of dealing with the EU as well as with bigger nations.

While Denmark is an EU member, Greenland as an autonomous realm left the EU in 1979. This was possible as Greenland was awarded the status of an overseas territory.



“The EU isn’t legally rigid but flexible and pragmatic,” said Ulrik Pram Gad a Greenland-born adviser to the Danish government. He proposed the opposite case for Scotland: England and Wales could leave the EU whereas Scotland and Ireland could remain. Gad named his idea “Engwaxid”.

Although not very likely, this is at least a new idea. And fresh ideas are highly welcomed by the Scottish government. “Leaving the EU is uncharted territory. And because it is uncharted territory we have to be creative and flexible”, says Hyslop.

At the moment nobody can tell how the Scotland-British border will look like after 2020. Whether it remains merely cultural or will become a factual one will depend on how much will and creativity the UK and Europe can summon up to avoid a hard Brexit.

