How is spousal maintenance calculated?

How the answer differs across 8 jurisdictions

The Short Answer

Spousal maintenance in Germany is based on the standard of living during marriage and the dependent spouse’s actual needs — not income sharing — and is limited by the principle of self-sufficiency under BGB § 1569.

Self-sufficiency
Core principle
Marital lifestyle
Basis for amount
Time-limited
Typical duration
Age/health/qual
Key factors
The Short Answer

Spousal support in Canada is not calculated by a fixed formula but determined case-by-case, based on the conditions, means, needs, and other circumstances of each spouse under the Divorce Act. Courts consider three main bases: compensatory, contractual, and non-compensatory (needs-based) support.

No fixed formul
Calculation method
3 support bases
Legal foundations
16 years
Moge v. Moge duration
Needs-based
Bracklow test
AustraliaFull article
The Short Answer

You may be entitled to spousal maintenance if you cannot meet your reasonable living expenses and your ex has the capacity to pay — but there is no automatic right based on income disparity alone.

2 years
Time limit after divorce
12 months
Time limit after de facto separation
Reasonable need
Key test for entitlement
Capacity to pay
Required from payer
The Short Answer

You can apply to court for maintenance from your spouse during separation under the Family Law Act 1995. The court will consider both spouses’ financial needs and resources when deciding the amount.

s. 7
Relevant section
1995
Enactment year
No time limit
Application timing
Circuit Court
Main court level
SingaporeFull article
The Short Answer

A wife's maintenance is determined by the court based on her needs, the husband's income and assets, and other factors in section 114 of the Women's Charter.

s. 114
Relevant section
Cap. 353
Act number
2009 Rev Ed
Latest revision
Reasonable need
Key factor
The Short Answer

There is no automatic right to spousal maintenance after divorce in the UK; the court decides based on need, resources, and fairness under section 25 of the Matrimonial Causes Act 1973.

No fixed rate
Calculation method
Case-by-case
Decision basis
Indefinite or t
Duration types
Section 25
Governing law
US-CaliforniaFull article
The Short Answer

California courts consider multiple factors including the length of the marriage, each spouse’s income and earning capacity, standard of living during marriage, age and health, and contributions to the other’s career or education.

10+ years
Long-term marriage
Indefinite
Support duration
$0–$5k/mo
Typical range
4320 factors
Statutory list
US-New YorkFull article
The Short Answer

You may be entitled to spousal support (called 'maintenance' in New York) if the court finds it appropriate based on factors like income disparity, marriage length, and each spouse’s financial circumstances.

Up to 50% of ne
Guideline cap
20+ years
Long-term marriage
15–30% of diffe
Temporary award range
Indefinite poss
Permanent maintenance

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Not legal advice. This article is general information based on publicly available sources, written for educational purposes. Laws change and individual situations vary. Consult a licensed attorney in your jurisdiction before acting on anything you read here. Last reviewed: June 2026.