Permeabilità giuridica attraverso il Mare del Nord? La rilevanza comparatistica del modello nordico di governo locale nella Scozia post-Brexit

The Nordic «kinship» of Scotland is based on secular relationships deriving from – among others – geographical proximity. In the wake of a possible second referendum on independence, the debate concerning a Scottish-Scandinavian identity in opposition to an English identity is back in vogue. The article questions the realistic possibility of an independent Scotland adopting a form of state in which welfare represents a social investment and where the system of local government serves this function. After a brief account of the history of relations between Scotland and the Scandinavian countries, the article identifies, on one hand, the specificities of the Nordic model of local government and, on the other, the characteristics of local government in Scotland. In conclusion, the article addresses the challenges that an independent Scotland would face if it adopted a Nordic-style social democratic form of state with specific attention devoted to local government.