For women taking time out from work to have a baby, maternity leave can be a wildly different experience depending on their place of residence. Women lucky enough to live in Sweden, Finland or Norway will receive 80% of their salaries for more than a year. They can also receive support from the father who has the option to take several months off work with benefits. But women in countries such as the US, Korea and Australia are not so fortunate and many struggle with no leave or financial support at all.

In general European countries, particularly EU member states, compare well internationally in terms of the benefits given to new mothers. Members of the EU these countries are obliged to give mothers a minimum of 14 weeks continuous maternity leave at a minimum wage rate set by the country of residence. According to an EU briefing note on maternity entitlements “Women on maternity leave are not necessarily entitled to full pay, but they are entitled to wage increases awarded prior to maternity leave or during it,” says the note. “The amount of the wage during maternity leave is determined by the legislation in the country of employment, but it must be at least equivalent to the wage paid during sickness leave.

Many countries go beyond the statutory minimum, Germany for example pays women 100% of salary for the full 14 weeks and pays 67% of salary for up to 12 months. This compares to just 6 weeks at 90% of salary in the UK, with up to 9 months paid at £123 per week. However the UK is working to strengthen domestic legislation and government ministers are currently debating proposals to extend paid leave from the current nine months to 12. Minister for women Harriet Harman insists the extension be effective from 2010 but other MPs representing business say the proposals would further damage the UK’s struggling economy.

At the same time the UK’s Equalities and Human Rights Commission wants to see the value of maternity allowances increased and for fathers to be given longer leave, beyond the current two weeks. In its Working Better report published this month, the Commission wants to see parents collectively given a full year of supported leave with the father eligible to take up to four months of this. Furthermore it says that the statutory minimum paid by businesses to working mothers should be 90% of salary for 26 weeks.

These proposals would cost the UK an additional £5.26 billion to implement in addition to the £2.07bn the country already spends on supporting mothers. Chief Executive of the commission Nicola Brewer says leave should be distributed more equally between parents, who in turn are given the flexibility to decide who is best placed to meet the needs of the children. This follows the model already used in countries such as Iceland, Norway, Sweden and Germany where fathers have the right to share leave with the mother.

“Changing the way we approach parental leave could be one way of tackling the gender pay gap,” explains Brewer. “By supporting men to be good fathers as well as good employees, it would also help children do better at school and equip them for the world of work. And it would help families on lower incomes to balance work and the rest of their lives.”

Not surprisingly most parents support the proposals. Emma Ward is a 31 year old Mother of seven month old Finley. She lives in Birmingham in the UK and currently receives statutory maternity pay of £123.00 per week after initially receiving 90 percent of her salary for the first three months. Her husband Dave took two weeks off work with the first week paid at 100% of salary but the second week unpaid. Emma says having time off together was much needed after a complicated birth. “I didn’t change a single nappy in the first two weeks, but I was recovering from the birth and had breastfeeding to battle with. I was so grateful that Dave could be there,” she says. “But his time with Fin was limited. More leave for Dads would be great.”

Caroline Cheetham lives in Leeds and is Mother to nine month old Alexandra. She is going back to work this month on a part time basis after taking the paid nine months plus an additional three months without pay. “I felt I really needed to be with her for 8/9 months but that was probably in part due to her reluctance to bottle feed so I could only breast feed. This last 3 months have been a bit of a bonus really – which is possibly why they are unpaid! However Alex is a big healthy girl. I guess I would feel differently if she has been sick or premature. We have coped well on statutory pay because we had some savings and because my husband earns a good wage. God knows how we would have coped when we were young and has less money.”

Increasing the statutory pay would cost businesses more and many are less than impressed with the additional cost burden. Some women are concerned that increasing the financial liability for firms will limit their career options. Caroline worries: “I think some firms would be much less likely to employ women of childbearing age.”

But if fathers were also taking leave this would reduce the likelihood of discrimination against women. “The idea of letting either parents take the leave is a good one,” says Caroline. “I think the difficulty at the moment is employer’s perceptions. Men who take time off work, or even time out from their social life are considered by some to be a bit ‘wet’! I guess the only way this will change is if it becomes the norm.”

Although the UK proposals would undoubtedly improve standard of living for working parents, the country has a long way to go until it meets the benefits granted in other countries such as Lithuania and Bulgaria. In both of these countries women are entitled to eight weeks sick leave before the birth at full pay, followed by two years leave on full pay in Bulgaria and a year on full pay in Lithuania.

But on the other hand, the proposals go a long way beyond what is available in countries such as the US and Australia where incredibly working mothers are not entitled to any paid leave. This is something that various lobbying groups are working to address. In the US lobby group Moms Rising has been battling to secure paid leave for working mothers. “In the US 49% of mothers cobble together paid leave following childbirth by using sick days, vacation days, disability leave, and maternity leave,” says a spokeswoman for the organisation.

Fortunately the US experience is not the norm and even here many private firms do offer benefits to new mothers. Worldwide it is fair to say that some form of paid leave exists almost universally, with three months at 80% to 100% pay being common. Beyond this there is generally a period of unpaid leave extending to up to 12 months. But it is European and Scandinavian countries in particular that have the best benefits including extended leave and paternity breaks for fathers. The good news is that other countries are paying attention and improving domestic legislation accordingly. But this can be a slow process and parents like Caroline who are planning to try for another baby may not see the benefits as soon as they would like. “I think I may move to Sweden,” she says.