Caught between domestic and international law: Scotland and Northern Ireland in a post-Brexit United Kingdom

The article analyzes the different implications of an “hard Brexit” on Scotland and Northern Ireland, keeping in consideration the obligations deriving from constitutional and international law for the two entities of the United Kingdom. In particular, the feasibility and the main implications of the processes enabling a future reacquisition of the EU membership, as well as several frameworks for a differentiated – and “softer” – Brexit, are separately assessed in order to identify the most prominent effects of the combination of domestic and international provisions in each of the two regions.