The future depends on the UK's new immigration policy

BRITONS living in France do so under the EU principle of free movement but a backlash against immigration and this principle was a driving force behind the Leave campaign, which said it had allowed record numbers of immigrants into the UK.

Britain will want to continue its access to the European Single Market, however the EU is likely to say freedom of movement is an intrinsic part of that market: the European Single Market is about the freedom of goods, services, capital – and people.

There is no country with both full access to the Single Market and restrictions on freedom of movement of people. Switzerland has made efforts to try, but the policy remains untested. In February 2014, it narrowly voted in a referendum to introduce quotas on immigration from the EU – flying in the face of its current treaty.

The vote commits the country to introduce quotas within three years but to do so would trigger a guillotine clause, automatically ending the deals it has with the EU on trade barriers and other areas such as agriculture, and science funding. The new quotas have yet to be implemented.

Britain imposes quotas

Leaving aside the contradiction of single market vs freedom of move­ment, the Leave campaign has stated that it wants an “Australian-style points based immigration system”.

A points system enables the government to allow people into the country to look for work based on whether they meet the criteria set out by central government, instead of whether a company has applied to bring that person in from abroad.

A statement by the Leave campaign says: “The automatic right of all EU citizens to come to live and work in the UK will end, as will EU control over vital aspects of our social security system.”

Applying such a system to EU citizens would reduce the number of immigrants arriving in Britain but raises questions about how other countries would respond. Assuming they respond in kind, people wanting to move to the EU (France) to work would have to fulfil certain criteria. The treatment of retirees wanting to head in either direction would also be part of these immigration quotas – although not linked to demands in the labour market.

UK does bilateral deals

There is always the option for the UK to do its own deals with individual countries – as it had with Ireland long before either country joined the EU.

However this runs counter to Leave promises of an immigration system that 'does not discriminate on the grounds of nationality'.

Such a deal with France could be struck (although the EU may attempt to block similar discussions) which would simplify matters for expats on either side of the Channel. Between France and Britain the general perception is that the French go to the UK to work and Britons come to France to retire. This arrangement of migration is asymmetric in terms of the cost and benefits to each country, so that could be another point of negotiation.

The Scottish Question

As Scotland – possibly even Northern Irland – moves to stay in the EU, it could be that only English and Welsh expats could be faced with these problems.