Scotland politics

Powerhouse Parliaments: is Holyrood the world's most devolved?

It has been an oft-repeated soundbite that Holyrood will become "one of the most powerful devolved parliaments in the world" once new powers are devolved under the Scotland Bill - with Scottish Secretary David Mundell the latest to use it in a speech in Edinburgh.

The phrase has proved controversial though, with one MSP insisting that it is "patently not true".

BBC Scotland studied some of the devolved governments of the world to assess where Holyrood ranks in terms of "powerhouse parliaments".


The Scottish Parliament

Image copyright PA

Part of: UK

Powers over: Some taxes and levies, policing, health, education, local government, housing, some welfare benefits, electoral system, agriculture

Powers reserved: Some taxes and duties, immigration, some welfare benefits, international relations and foreign policy

Fiscal powers: Mixed

Own currency? No

The Scotland Bill adds to Holyrood's powers on a number of fronts, from a share of VAT receipts to greater control over income tax. This adds to the devolved administration's authority over policing, health and education, among other matters. However, Deputy First Minister John Swinney has said 86% of welfare powers will remain under the control of Westminster, while matters such as immigration and foreign policy are also reserved.


Northern Ireland

Image copyright Wknight94

Part of: UK

Powers over: Justice, policing, agriculture, education, health

Powers reserved: Tax, international relations and foreign policy, elections

Fiscal powers: Mixed

Own currency? No

The Northern Ireland Assembly has had a rocky history; it was set up and abolished several times before the current assembly was established in 1998, but has been suspended several times since. There are two types of powers not devolved to Stormont; reserved matters, such as civil aviation and postal services, which may someday be devolved, and excepted matters, like defence and foreign policy, which are not expected to be devolved at any point. Financial powers are mixed - Northern Ireland has control over corporation tax, but not income tax.


Wales

Part of: UK

Powers over: Agriculture, education, culture, welfare, industry, housing, tourism

Powers reserved: Defence, constitution, international relations and foreign policy

Fiscal powers: Some

Own currency? No

The Welsh Assembly had very limited powers when it was first set up, but its legislative competencies have grown since. It was given law-making powers in 2006, and won permission to legislate on 20 devolved areas without having to consult Westminster in 2011. Some borrowing powers have been devolved to the Senedd, along with control of stamp duty and landfill tax. While the assembly does not have the ability to set a degree of income tax, the 2014 Wales Act means it could win this power via a referendum.


German Länder

Part of: Germany, a federal republic

Powers over: Education, policing, local government and culture

Powers reserved: Foreign affairs, defence, tariffs and indirect taxes

Fiscal powers: Control some taxes, but rates set centrally

Own currency? No

Germany's regional governments technically have a reasonable degree of autonomy, holding power over education, policing and culture and sharing responsibility for public welfare, agriculture and economic affairs. While they have control over a decent percentage of expenditure and revenues (although less than is devolved to Holyrood), rates and bases are set centrally and cannot vary across the Länder.


Canadian provinces

Part of: Canada

Powers over: Healthcare, education, welfare, transport

Powers reserved: Foreign policy

Fiscal powers: Strong, although somewhat reliant on grants from federal government

Own currency? No

Canada has a federal structure which entrusts governments in each of its ten provinces and three territories with many important public services, administered via regional parliaments. Canada's provinces have greater control over local expenditure and revenues than Holyrood has under the Smith Commission - but funding is sourced from the central government via "transfer payments" as well as local taxes, meaning the government can impose federal mandates to influence what regional governments do.


The Faroe Islands

Image copyright Stig Nygaard

Part of: The Kingdom of Demark

Powers over: Most domestic matters

Powers reserved: Defence, policing, justice, currency and foreign affairs

Fiscal powers: Largely devolved, although receives annual subsidy from Denmark

Own currency? Yes - although the Faroese krona is pegged to the Danish krone

The 18 Faroe Islands have been self-governing since 1948. The Faroese parliament, the Løgting, has wide domestic powers, as well as some powers over international affairs and diplomacy, with missions to Iceland and the EU. However, a number of areas including policing and justice are reserved to Copenhagen. The islands receive an annual subsidy from Denmark making up about 3% of GDP.


Spanish regions

Image copyright Luis Javier Modino Martínez

Part of: The Kingdom of Spain

Powers over: Health, education, social services and culture

Powers reserved: Foreign affairs, defence, import duties and VAT

Fiscal powers: Some regions have financial autonomy

Own currency? No

Devolution is different in different regions of Spain, which is divided into 17 autonomous communities and two autonomous cities. More devolved areas like the Basque Country have responsibility for all taxes except import duties and VAT. The regions control large percentages of expenditure and revenues, although still less than Holyrood will receive under the Smith recommendations.


Åland Islands

Image copyright Eivind Sætre

Part of: Republic of Finland

Powers over: Language, policing, postal system and regional government

Powers reserved: Foreign relations, taxation and duties

Fiscal powers: Limited

Own currency? No (although Swedish krona widely accepted)

The Åland Islands is an archipelago of 6,757 islands in the Baltic Sea between Finland and Sweden. The islands have autonomous status and a 30-member parliament, and are guaranteed representation in Finland's parliament. The Åland government controls local matters, but taxes and duties are collected by the Finnish government, which then gives money back to the islands via a block grant.


Aruba, Curaçao and Sint Maarten

Image copyright Rodry 1

Part of: Kingdom of the Netherlands

Powers over: All local matters

Powers reserved: Foreign policy, defence and human rights

Fiscal powers: Yes, although some development aid from Dutch government

Own currency? Yes

The three Caribbean islands are technically equal partners in the Kingdom of the Netherlands, although in practice most Kingdom affairs are administered from the European country. Aruba, Curaçao and Sint Maarten have their own parliaments and are autonomous to a large degree, including an increasing degree of financial independence.


Zanzibar

Image copyright Wegmann

Part of: United Republic of Tanzania

Powers over: Agriculture, health, education, industry and land

Powers reserved: Defence, policing, immigration, external trade, citizenship and tax

Fiscal powers: Limited

Own currency? No

Zanzibar is a semi-autonomous archipelago off the coast of Tanzania in East Africa. It has its own constitution and government and passes laws and makes decisions on local issues, and has representation in the National Assembly of Tanzania. Taxes are collected by the Tanzanian government and a block grant returned to Zanzibar, the size of which has caused controversy. Elections to the local authority in 2000 and 2005 were marred by violence, which led to a multi-party system being introduced in 2010, when a national unity government was elected.


Swiss cantons

Image copyright John Doe

Part of: Swiss Confederation

Powers over: Healthcare, welfare, policing, education and taxation

Powers reserved: Foreign policy, defence, railways and currency

Fiscal powers: Extensive

Own currency? No

Switzerland's 26 cantons have a high degree of independence, with the federal government's jurisdiction limited to a few areas defined in the constitution. The Swiss system is close to being a direct democracy; a referendum must be held for any change in the constitution, and referenda can be requested for any changes to the law. The federal government, cantons and local communities all levy taxes, to an almost equal degree, and local control over revenues and expenditure is slightly greater than Holyrood will have under the Smith Commission powers.

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