Simply, the pay and conditions are better in Scotland.
Many teachers in England are ok with the pay, tbh. It's the conditions that are the issue. If the conditions were better, the pay would feel enough. If the pay were better, the conditions would feel more acceptable.
Teachers in Scotland are contracted to work 35hours pw with 7.5hours non contact time (for preparation and assessment etc).
Teachers in England are contracted to work 32.5hours with 2.5 hours preparation and assessment time.
Total hours worked are probably similar but teachers in Scotland have higher salaries and are paid for more of the work they do.
And the curriculum.is different.
There are many reasons why teaching in England is hard. One of the main ones I've observed is that a lot more time used to be spent in EYFS and KS1 on PSHE issues. Not necessarily in terms of taught curriculum but TAs were available to work with children on friendship and behavioural issues on an ad hoc basis. Or to lead phonics, for example, whilst the teacher did. There was a lot more focus on things like circle time and listening, building a sense of community in class.
Now, TAs are fewer and we have no class based TAs in my school outside of Reception and the focus is all academic. TAs used to fulfill a very important pastoral role in class or be an extra adult to allow the teacher to.
Without this, we see a lot.of low level issues creeping into KS2 around things like poor conflict resolution skills and low resilience that would have previously been addressed in the lower school. As a result, behaviours for learning are poorer alongside increased curriculum content and higher expectations.
The curriculum, as it stands, requires chidren to be regulated and ready/wiling to.learn at all times and the reality is they're not. Because they're children and everything feels huge to them.
That creates increased stress and pressure for teachers who can't afford the time to have a chat with the class or to do an ad hoc pastoral activity because then you'll be even further behind in a curriculum that already can't be taught in the time available.
The children have heightened nervous systems and the teachers have heightened nervous systems.
"Jessica said she isn't my friend anymore," used to feel/be easy to deal with and an important part of educating children on navigating social relationships. Now it's just something that gets in the way of the curriculum. And you've always got an eye on that.
And that's partly why the system is failing. Children aren't empty vessels waiting to be filled with knowledge. They're small people with complex emotions, a range of personal experiences and needs and these are often impossible to meet appropriately when the curriculum is so demanding and there is only 1 adult in class.
Gone.off on a bit of a tangent there! But it's relevant.
ETA I'm also hearing 'exposure to the curriculum' a lot now. If the content can't be accessed, if the childen haven't learnt it (because it's a concept that is beyond their age and understanding) because there was more to cover in the lesson than could be taught effectively in the time available - we are told not to worry, it's just important that they've had exposure to the curriculum.