Opinion: Scotland once boasted its own distinct regional building styles, but since devolution began in the 1990s Scottish architecture has fallen foul of the profit-chasing short-termism that has blighted the rest of the UK, says Owen Hatherley.

The United Kingdom is one of the last of the big multinational empires, a country made up of (at least) four distinct nations. American commentators used to call the old Union of Soviet Socialist Republics the "prison house of nations". A multinational empire is often supposed to be a prison house of some specifically national architecture. Yet even in the Union, the first thing an English visitor to Scotland will always notice, aside from the banknotes, is how different its architecture and its cities are to the English.

The materials – the hard, vivid red and yellow sandstones – the love of metropolitan scale – tall tenements, grid plans – and the overall sense of sublimity, with nothing village-like in the city, are obvious in Edinburgh, Glasgow and Aberdeen, but are not common qualities in Leeds, Manchester and Birmingham. Aside from freaks like the odd red-brick Mancunian mill on Clydeside or the suspiciously Glaswegian Barrow Island in north-west England, architecture was independent even during the Union's Victorian peak. Would independence make any difference to this? It shouldn't influence voting in any way – Scots have more important things to think about in pondering their choice – but what might the future of Scottish architecture be in an independent state?

The evidence both from the nations that left their "prison house" in the 1990s is mixed. "National" styles and what could be called, after Kenneth Frampton, "critical regionalist" architecture, flourished in Soviet-dominated Europe in the 1980s, much as it did in the late Hapsburg Empire, or in post-Franco Catalonia and post-Salazar Portugal around the same time.

This took various forms, inflected by the culture of each region. The Baltic States favoured an Aalto-esque small-scale Scandinavian modernism over Soviet monumentality, seemingly as a gesture towards its wealthy, comfortable neighbours with the implicit suggestion that if only they hadn't been annexed in the 1940s, the Baltics would be in the position of Finland.

Yet the most interesting architects, such as the Estonian Raine Karp, owed little to either Aalto or to Soviet precedent, creating harshly original buildings – such as the National Library in Tallinn – that seemed to emerge from the landscape, or were themselves landscape, such as the Linnahall on the Baltic sea itself. Likewise, Central Asian, Georgian or Azerbaijani architects favoured adaptations of modernism to their own particular climate, with or without a skein of local "reference" draped over it. Yet few of these countries managed to maintain this originality after 1991, preferring either either good taste western pseudomodernism (in the Baltics) or monumental neo-Soviet bling (everywhere else).

A contrasting example is Hungarian Organic Architecture. Flourishing at the turn of the '90s, this style and its exponents – most famous being the late Imre Makovecs – favoured tapering, wormlike or phallic forms allegedly inspired by the Yurts carried by nomadic pre-medieval Magyars. In Makovecs case, "national style" corresponded with passionately held and deeply unpleasant nationalist convictions.

If Scotland does become independent, it will be ruled from a building designed by Catalan architects: Enric Miralles and Benedetta Tagliabue's Scottish Parliament, unveiled to some controversy after the obligatory cost overruns in the early 2000s. Both its provenance – from Catalonia to Scotland, from one semi-autonomous nation claiming its rights to another – and its scrupulously unique, individualist design were very deliberate moves towards a style that was both locally specific and outward-looking. In this, it's possible to argue that EMBT's building was in a certain Scottish internationalist tradition; certainly it looks a great deal more progressive than Michael Hopkins' stodgy Porticullis House, designed for British Parliamentarians in London around the same time. It could be placed in a lineage with the way that Glasgow architecture in the early 20th century was far more open to outside influence than the architecture of London or Manchester.

Any visit to what was once the Second City of Empire in terms of power, population and influence shows its closeness to Chicago, Stockholm or Berlin is far more apparent than any closeness to London. Glasgow architecture from the 1880s to the 1920s, whether steel-frame classicism or perpendicular art nouveau, is strikingly unlike the Queen Anne, French baroque or Arts and Crafts styles fashionable in the capital, and vastly more convincing as confident, metropolitan architecture. And famously, in the case of Charles Rennie Mackintosh and his fan club in 1910s Vienna and Berlin, Glasgow's architecture went on to influence the development of the Modern movement on the continent. Yet at this point, the city, and the country in general, was ruled from a Scottish Office in Whitehall.

Since devolution began, after some false starts, in the late 1990s, is much less easy to differentiate Scottish architecture from English. This isn't the fault of devolution itself – apart from that continued revelling in sublime scale, there's not much in Scottish modernism to differentiate it from English, aside maybe from a certain regional rhetoric in some of the buildings of Basil Spence and his ilk. The architecture of the late Izi Metzstein and Andy Macmillan was regional in the sense that it was fitted to its site, climate and materials, but you can find them doing much the same thing in Cambridge or Hull. Scottish new towns like Cumbernauld were lushly integrated into the landscape, as were the first phases of Milton Keynes in England.

But the panorama of Scottish architecture in the '90s, 2000s and 2010s is the same landscape of tacky, multi-materials luxury flats, botched non-planning and iconic grand projects that you would find in the north of England at the same time. The largest scale developments, such as Edinburgh Harbour in Leith or the redevelopment of the Clyde with call centres and luxury flats, have been indistinguishable from contemporary practice in Bristol or Birmingham, as are the closes of anti-urban cul-de-sacs on the edge of every Scottish city.

It all shows a profit-chasing short-termism, architectural compromise and urban ineptitude that feels distinctly Anglo-Saxon. Investment has been directed to Edinburgh, which boasts some monstrous postmodernist banks, but there has been absolutely nothing in Glasgow since the 1970s to show anything remotely resembling the fearless monumentality and harsh rectitude of its finest buildings.

This is not an argument against Scotland's independence, which is it's own business. Scotland's urban traditions are far closer to contemporary European norms than is contemporary English practice, and greater local government should give them the opportunity to develop this. Yet the experience of devolution shows that the full neoliberalism of a government in London or the tempered neoliberalism of a government in Edinburgh may have rather similar effects on architecture and the city.

Owen Hatherley is a critic and author, focussing on architecture, politics and culture. His books include Militant Modernism (2009), A Guide to the New Ruins of Great Britain (2010), and A New Kind of Bleak: Journeys Through urban Britain (2012).