A ski resort in Italy, a set of Swedish-language islands in Finland and a Spanish city in Africa could hold the key to Northern Ireland’s future post-Brexit, an Irish MEP has said.

They are among more than a dozen territories in, or linked to, the EU which have special legal status within the bloc allowing them to be half in and half out of the EU tax and customs union.

One solution mooted for Northern Ireland is for it to remain in the customs union, which allows tariff-free trade among all member states, even if the UK pulls out.

This would not be acceptable to the Democratic Unionist party, which has said it does not want “special status”, but Marian Harkin, the independent MEP for Ireland’s North West constituency, is among a growing body of Irish politicians frustrated that alternatives are not being put on the table by Westminster despite the unanimous desire for a soft border between Northern Ireland and the Irish Republic.

Harkin says Ireland has to look to other territories in Europe for inspiration.

“We are running out of time … many other models exist across the EU. Special status, unique solutions, whatever you like to call them exist throughout the EU, and we need to start crafting ours,” said Harkin.

“I believe we cannot wait for the EU to come forward with proposals. We on this island need to work together and we need to find solutions,” she said, citing Vatican City, the Aland Islands in Finland and two tiny communities in Lombardy in Italy that have tailor-made trading arrangements with the EU.

The microstates, enclaves and overseas territories that have special status, listed below, show that despite the EU’s apparent rigidity, history can force through quirky solutions.

Aland Islands

The Aland Islands in Finland. Photograph: Hemis/Alamy

A self-governing Swedish-speaking region of Finland with special status in the EU. The islands are in the EU and the customs union but EU VAT and excise duties do not apply. Duty free sales are allowed for passengers travelling between the islands and mainland Finland.

Campione d’Italia

Lake Lugano, Campione d’Italia. Photograph: Alamy Stock Photo

An Italian enclave, 40 miles north of Milan, surrounded by Swiss territory. Although part of the EU, it is not in the customs union or VAT area. The Swiss franc is the legal tender although euros are also widely accepted.



Livigno

Livigno in Lombardy, Italy. Photograph: Alamy Stock Photo

A ski resort, with a population of around 7,000, on the border of Switzerland but in the Italian region of Lombardy. It enjoys a special tax status, outside the customs union and the VAT area. The customs post on the Swiss border is manned by Italian and Swiss officials.



The Spanish enclave of Ceuta in north Africa. Photograph: Desmond Boylan/Reuters

These two Spanish territories on the north coast of Africa are in the EU but outside the customs and VAT area of the EU trading bloc. However, because of preferential rules, no customs charges are levied on goods crossing to or from the EU.



San Marino. Photograph: Alamy Stock Photo

One of the smallest nations in the world, but forward thinking: this week it was revealed to be on course to be the first country to have 5G mobile network. An enclave surrounded by Italy, San Marino is not in the EU, but is in the customs union for all products except coal and steel. Could Northern Ireland, which is facing high tariffs on agriculture products, pursue a partial customs union arrangement like this?



Andorra la Vella, capital of Andorra. Photograph: Robert Harding/Rex/Shutterstock

A so-called microstate between France and Spain. It is not in the EU but has a customs union agreement, exempting it from duties on everything apart from agricultural produce. There are customs checks on both sides of the border because of its low VAT and tax on goods such as alcohol and cigarettes. Tobacco smuggling was a huge problem until it was made an offence in Andorra and at its peak in 1997 Spanish police guarded all the mountain tracks and paths on its border. Smuggling is already an issue in Ireland because of the fluctuating pound/euro exchange rate and was a source of income for the IRA, so will be nothing new to authorities there.



Monaco

Port Hercules, Monaco. Photograph: Bloomberg via Getty Images

A tiny independent city-state on the French riviera, best known as a playground for the rich, with its upscale casinos, and a tax haven. It is not in the EU but is part of the customs union through a customs agreement with France. It’s hard to see Northern Ireland mimicking the pleasures of Monaco, but could the UK seek a similar arrangement?



Liechtenstein

The Castel of Vaduz in Liechtenstein. Photograph: Fabrice Coffrini/AFP/Getty Images

Not in the EU, but Liechtenstein is in the European Economic Area, which makes it part of the single market. It is not in the EU customs union, but is within the EU internal market and applies certain EU laws.

French overseas territories

Guadeloupe. Photograph: Alamy

Guadeloupe, French Guiana, Martinique, Réunion, Mayotte and Saint Martin are all in the customs union but VAT and excise rules do not apply.

Channel Islands

The bailiwicks of Jersey and Guernsey are British crown dependencies. They are not part of the European Union but are part of the customs union as part of protocol 3 of the UK’s 1972 accession treaty. When the UK departs the EU that accession treaty will no longer hold, pushing the Channel Islands, like Northern Ireland, out of the customs union.

Neither Britain and Ireland nor the EU want a return to a hard border in Ireland, with widespread concern it could imperil peace secured in the Good Friday agreement almost 20 years ago.



Simon Coveney, the Irish foreign minister, has warned that technical solutions will not solve the issue of the Irish border.

“What we do not want to pretend is that we can solve the problems of the border on the island of Ireland through technical solutions like cameras and pre-registration and so on.

“That is not going to work,” he told reporters in Brussels this week.