A Comparison of Child Support Schemes in Selected Countries
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Introduction
This chapter gives an overview of how child support schemes operate in selected other countries, of the contexts of these schemes in terms of government assistance and interaction with family law, and of the major problems and positive factors of the schemes. The UK, Canada, and NZ were chosen for comparison because they share with Australia the British tradition of law; Norway was chosen as a contrasting system that provides "advance maintenance" and explicitly assigns child support liabilities on the basis of set costs of children; and the US was chosen because our current scheme was based upon theirs, and for the policy contrast it provides. These countries are all similar to Australia in that they generally calculate liabilities using a formula as at least a guideline, if not as an absolute prescription. The majority of other countries do not have a child support scheme or agency as such; instead, they largely rely on discretionary court awards.
In almost all countries, and certainly in all the countries reviewed here, government helps families with some of the costs of children, whether this be through tax subsidies or cash benefits or through the provision of goods such as public education, health, and transport. However, the level of assistance to families varies widely, in line with differing views on the appropriate mix of public and private contributions to the raising of children and to support of individuals. It would therefore be unreasonable to examine the various child support systems in isolation from their wider social policy and legal background.
Historically, there has been a much higher level of government contribution (and of taxes paid to government) in countries with leftist governments and with more homogenous populations. Sweden and Norway fall into this category, though to a lesser extent now than a generation ago. The United States is at the other end of the this spectrum, at least amongst the countries surveyed. Countries with lower birth rates also tend to provide more generous family benefits. In addition, more ambitious social policy/extensive social reform is usually to be found in countries with central governments, such as Sweden, rather than in federations of states or provinces, particularly where the states are wary of federal government "interference". This wariness seems to be greater in the United States than in Australia or Canada.
Of course, it is always difficult to make international comparisons of complex structures such as a child support scheme or family benefit regimes, where the tax, law, welfare, education, and health systems are all involved. Countries do not necessarily collect the same data in the same way, and some factors, such as community values, are problematic to measure or analyze, let alone compare. In addition, benefits provided to families may vary greatly between high- and low-income families, single- and dual-income families, and families with different numbers of children, so it is difficult to ascribe a particular "level" of benefit to a country. This chapter aims, therefore, to give a reasonable impression of the child support system and related issues of various countries, rather than strict comparisons of dollar amounts paid, for example.