LOCAL TAXATION IN OTHER COUNTRIES Some knowledge of the local government system of a country is obviously essential to the understanding of its method of local taxation. This is not the place for an attempt to explain, however briefly, local government systems, but it does seem necessary to allude to one or two characteristics which have a bearing upon the local taxation and in which the systems of other countries differ essentially from that of Great Britain.
primary area of local government on the con tinent of Europe may be most conveniently described by the French word "commune." Almost invariably, the whole area of a country is divided into communes and these, whether urban or rural, whether large or small, have usually the same status and the same powers and duties. The only exception to this rule is that, in Germany and some other countries, certain of the larger towns are made independent of any other local authority, as is the English county borough of the county. The secondary area of local government, answering to the English county, is known as a "department" in France, as a "circle" in Germany, as a "prov ince" in Belgium, Holland, Italy and Spain, and by various titles in other countries. It has usually a more organic connection with the commune than has the English county with the minor authorities; is more generally entrusted with control over these latter, especially in finance ; and is looked upon rather as an agglomeration of communes for the wider purposes of administra tion than as having a separate existence of its own.
These two types of areas have each their elected local authorities with powers of local self-government, but side by side with these is to be found, almost invariably, a system of State local govern ment, which may be carried on either by a completely distinct set of authorities or by employing officials of the local authority also as agents of the State. By this means the administration of the police is almost always completely withdrawn from the sphere of local self-government, the term "police" frequently signifying, not merely "security police" but the making and enforcing of any regulations (such as public health or building by-laws) whose infraction involves penal procedure. Moreover,
in the more completely centralized countries other matters than police are regulated locally by the central Government or its agents—as for instance, education in France, where, although local taxation is called upon to contribute to a certain extent to the expense, the whole cost of the salaries of teachers is borne by the central Government and does not appear in the local budgets.
It follows from this that it is seldom possible to draw the same hard and fast line on the continent, as in England, between the purposes or the objects of national and local taxation ; and that the whole conception of local taxation is different. It is, indeed, held in some quarters that a system of local finance should, as far as possible, include all kinds of impositions which are found in the State system and be, in effect, a reduced reproduction of that sys tem, in order that all taxpayers and all revenues may be called upon to contribute to the local charges. In no country is this principle fully carried out, but there is almost everywhere a very close connection between the respective local and national systems. This is especially the case in Germany since the World War. The various States of the German Confederation (or "Reich") have each the power to organize their own system of local government and finance, subject, however, to certain general rules laid down in the national constitution and by subsequent national legislation. The general effect of these rules is that, in the hierarchy of Reich, States, provinces, circles and communes, the higher author ity has the prior right to any sources of public revenue and the communes have to do the best they can with what remains to them after the superior authorities have made provision for their needs.