In times like these, with empty coffers in the wake of financial and economic crises, governments have an eye out for new sources of income.

Reintroducing a wealth tax could be one of them, and is currently the talk of the town in Germany.

Opponents say a return of the country's wealth tax would have a relatively minor effect, however. Martin Lenz, head of National Tax at Germany's KPMG auditing and advisory firm, doubts any appreciable assets would be left after subtracting administrative costs. Both the taxpayer's and the fiscal authorities' costs must be considered, Lenz told Deutsche Welle.

As countries across Europe are currently holding the same debate, KPMG seized the opportunity to compare German tax laws with wealth taxation in France, Italy, Britain, Austria, the Netherlands, Switzerland and the US. The study investigated general wealth taxation and wealth-related taxes, including property, inheritance and gift tax. These are part of the wealth tax - a fact that is often forgotten in the current debate, Lenz says.

Frontrunner France

Wealth-dependent taxes in the countries KMPG compared merely amount to between 0.07 to 5 percent of national tax revenue. The difference in taxation systems plays a role, too, says Lenz: in Germany, revenue from property, inheritance and gift tax comes to about 16.5 billion euros per year. "That amounts to about 2.8 percent of Germany's entire tax revenue," the German tax expert says.

Germanyis in the middle range of the countries KPMG examined. France - which introduced a wealth tax in 1982 - is at the top of the list and is the only EU state to impose a wealth tax, although Switzerland - outside the EU - also has one.

"Altogether, France's revenue from wealth tax amounts to about 8.6 percent of all tax revenue," Martin Lenz points out. "At the same time, productive company assets are largely exempt from the tax and corporate entities are not at all subject to wealth tax."

Other EU states never had a wealth tax or abolished their versions of the levy over the years. Britain has no general wealth tax, although there is an ongoing debate about an extra "mansion tax" on high-value homes. The Netherlands abolished its wealth tax in 2001 due to public opposition and Austria cancelled its wealth tax in 1993 as a result of assessment problems. Italy is not considering a wealth tax, arguing the operating expenses would be too great and revenue too small.

Property taxes

The US, on the other hand, levies property taxes, Martin Lenz says. They amount to about 12 percent of the national tax, Lenz explains, which in turn is used to finance "almost all communal functions such as police, fire departments, schools and street cleaning."

The KPMG study comes to the conclusion that in all countries surveyed, administrative costs to determine wealth-related taxes are higher than to ascertain other tax types. In fact, according to US estimates, the administrative expenditure to ascertain estate and gift tax just about equals the revenue they generate.

In Germany, the government repealed the wealth tax in 1997 following a ruling by the Constitutional Court that demanded equal taxation of all property. To date, however, no sound and above all comprehensive evaluation system exists for real estate or other assets such as shares in a company, a work of art or a yacht in the Mediterranean.

Reviving the general wealth tax is a legally delicate matter in Germany - one that is not likely to be resolved quickly.