How is spousal maintenance calculated?
How the answer differs across 8 jurisdictions
GermanyFull article 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.
CanadaFull article 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.
AustraliaFull article 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.
IrelandFull article 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.
SingaporeFull article 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.
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.
US-CaliforniaFull article 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.
US-New YorkFull article 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.
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GermanyHow is spousal maintenance calculated after divorce?
CanadaHow is spousal support calculated and what factors does the court consider?
AustraliaMy ex earned much more than me during our marriage. Am I entitled to spousal maintenance?
IrelandI want maintenance from my spouse during separation.
SingaporeHow is maintenance for a wife determined?
UKWhat spousal maintenance can I expect after divorce?
US-CaliforniaWhat factors does the court consider for spousal support?
US-New YorkAm I entitled to spousal support (maintenance) in New York?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.