Pubblica amministrazione e Terzo settore: Un inquadramento comparatistico [Public Administration and the Third Sector: A Comparative Framework]

This article offers a comparative analysis of the relationship between public administrations and Third Sector organisations (TSOs). Starting from the conceptual difficulties inherent in defining the object of comparison, the study adopts functional criteria capable of transcending national legal categories. It situates the evolving role of the Third Sector within broader transformations of the State, from the liberal model to the democratic-social State, characterised by constitutional pluralism and solidarity. The article examines three core administrative functions recurrent across legal systems: public control over TSOs, public financing and favourable tax regimes, and collaborative arrangements for the delivery of services of general interest. Particular attention is paid to the tension between these practices and European Union law, especially competition rules and State aid discipline. The analysis shows an emerging convergence towards cooperative models that reconcile social objectives, administrative transparency, and fiscal sustainability.