Separation of church and state: the position outside Australia

Separation of church and state: the position outside Australia

Frank Mobbs

In the last issue, Frank Mobbs discussed the issue of separation of church and state in Australia , showing the constitutional foundation for this separation, and how many people confuse it with secularism. In this article, he examines how these issues are dealt with in some comparable Western countries.

The United Kingdom is very similar in matters of law and social relations to Australia, so we start with it. As we all know, the Church of England is the Established Church. What does this amount to?

The Church is not funded by the government, neither clergy nor buildings. Its schools are funded as are other religious and secular schools, though it operates schools fully funded by charging fees.

Its bishops have the privilege of conducting important ceremonies, such as coronations and national funerals. Bishops are appointed by the Prime Minister without apparent harm to the Church.

The monarch is head of the Church but exercises no authority over it, similarly to the way she exercises her authority in Australia. Twenty-six of her bishops sit in the House of Lords out of a total of 789 members.

It would make little difference to the Church of England were it dis-established and it is hardly a threat to democracy in the United Kingdom.


There is no established Church in Germany. A close connection between Church and State is provided by the Kirchensteur. This is a tax whose proceeds go to certain registered Churches, mostly Lutheran and Catholic.

Presently the tax is levied on all forms of income, be that wages, salaries, dividends or any other form of monetary gain.

It is raised as usually 9% of an applicable income tax but capped not to exceed between 2.75% and 3.5% of taxable income. In some instances it is levied at a flat rate of between 4% and 7%.

The tax is payable by all citizens deriving income of any sort, from any source.

Taxpayers indicate on their income-tax registration forms their religious affiliation. They can only nominate a denomination recognised as a legitimate Religiöse Körperschaft (religious corporate body).

This disallows distributions to some 'questionable' sects. Some legitimate communities, however, voluntarily forgo the right to receive the tax, e.g. the Salvation Army, the Quakers, Christian Scientists, et al. These groups rely entirely on contributions from members and public appeals.

The tax is collected by employers in the case of wages or salaries, by banks and financial institutions for payment of dividends, etc.

If a taxpayer declines to nominate a religious denomination on his tax registration he is not taxed. The respective state taxation offices retain portion of the taxes collected for their administration before handing the monies over to the churches, i.e., a diocese or regional church office.

In 2012 the amounts of tax collected were on behalf of the Lutheran Church €4.3 billion and on behalf of the Catholic Church €5.2 billion.

From this income the Churches pay their clergy and build and maintain church buildings, though some projects necessitate fund raising by Churches.

This frees their members to fund overseas aid. The Catholic Church's agency, Misereor, is outstanding for the aid it sends to poor countries. It spends hundreds of millions of euros each year on overseas projects.

Education is the responsibility of the 16 federal States ( Bundesländer), and each State can decide how to organise religious education. In most states, religious education is obligatory. The curriculum is provided by the Churches and approved by the State.

Children whose parents do not want them to participate in religious education are obliged to attend an alternative class called "ethics".

Can you imagine Australians receiving tax assessments which routinely include Church tax? We note that in Germany there is little of the nervousness exhibited by some Australians over separation of Church and State.

Among other European countries Austria has a compulsory Church tax, with a rate of 1.1%. 14 legally recognised Churches and religious groups share the proceeds.

In Switzerland there is no official state church. However, all the 26 cantons (States) financially support at least one of the three traditional denominations – Catholic, Old Catholic, Evangelical (Reformed) – with funds collected through taxation.

In some cantons, the church tax (up to 2.3%) is voluntary but in others an individual who chooses not to contribute to church tax may formally have to leave the church.

All members of either the Lutheran Church or Finnish Orthodox Church (the two state churches of Finland) pay an income-based church tax of between 1% and 2%, depending on the municipality. On average the tax is about 1.3%.


France is renowned for its government's policy of laïcité. This means that the constitution prohibits the State from supporting any religious group. In addition, most French governments since 1905 have pursued policies hostile to religion especially that of the Catholic Church.

However, the separation is not at all complete. In fact, heavily state-subsidised religious schools still educate about one-fifth of all French children.

The Catholic universities receive about 33% of their income from the State which recognises their degrees. In Alsace and Moselle where the Concordat between France and the Holy See still prevails, Catholic priests as well as the clergy of three other religious groups (Lutheran, Calvinist, and Jewish) are paid by the State, and schools have religion courses.

In Wallis and Futuna, a French overseas territory, national education is conceded to the Catholic diocese, which gets paid for it by the State.


Our canter through some European nations shows that relations between governments and religious groups vary widely but that close co-operation is common.

Dr Frank Mobbs' email address is

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