Gender Equality, Taxation, and the COVID-19 Recovery: A Study of Sweden and Denmark 

The impact of COVID-19 is undeniably extensive as the world faces the most severe recession in nearly a century. Emergency economic programs, COVID-19 tax policies, and subsequent state aid actions have been launched in many countries to mitigate the effects of the pandemic. This human crisis coincides with the 25th anniversary of the U.N.’s Beijing Platform for Action, an effort undertaken based on the Convention on the Elimination of All Forms of Discrimination Against Women.

The U.N. intended for 2020 to be a groundbreaking year for gender equality initiatives. Instead, the U.N. claims that the ongoing pandemic has put at risk the limited gains that have been made regarding gender equality. Women will be hit the hardest, and they will also be the backbone of recovery strategies in their communities. This is why U.N. Secretary-General António Guterres has pointed out the need for women’s equal representation and participation in the design of COVID-19 support programs. He underlines the importance of undertaking socioeconomic gender impact assessments of fiscal stimulus and social assistance programs and the potential to use these programs to drive transformative change.¹

A growing number of (mostly) country-specific reports are now giving evidence for the U.N.’s risk analysis. Unlike previous economic recessions or financial crises, sectors of the labor market traditionally dominated by women — such as healthcare, education, child care, retail, and client-facing services, all of which are characterized by low-paying and often part-time jobs — seem to have been hit the hardest by the pandemic. These sectors have, as emerging data suggest, experienced higher job losses than traditionally male-dominated sectors and appear to be inadequately covered by most financial state aid schemes.

Women have, relative to men, reduced their hours of work more significantly to care for and homeschool children, a trend that only aggravates existing problems associated with both the loss of paid work hours and the gender-segregated allocation of unpaid hours for household work and family care.² The sudden closure of child care programs and schools in many countries has had a crucial impact on women whose labor force participation depends on these institutions.³ Based on studies of how the unequal intra-household distribution of paid and unpaid work creates disincentives for the labor market participation of the secondary-earner, child care closures make it extremely likely that married women in particular may be slower to reenter the workforce.⁴

One must also consider existing gender gaps within domestic tax systems and national tax policies. Even before the pandemic, domestic tax systems inherently worked against economic gender equality, despite the impressive growth experienced by many economies in recent years. Although most tax systems use gender-neutral wording in their legislative texts, tax systems and fiscal policy decisions affect men and women differently when the tax acts are actually applied. Therefore, many aspects of taxation have an indirect but substantial effect on gender-related socioeconomic inequalities. These differences persist not only in employment rates, but also in general patterns and gender gaps in unpaid care work. Employment rates, income, old-age security, poverty, and wealth are all closely linked to the allocative and distributional outcome of tax regulations. Previous research on gender and taxation has established that the structure of women’s socioeconomic vulnerability is closely connected to the cultural patterns of caring, subordination, and oppression.⁵

The absence of perspectives on gender equality in tax policies and reforms is striking. In this context, the U.N.’s Agenda 2030 has been an eye-opener. Some influential tax policy organizations, including the U.N., the OECD, and the IMF, have come to recognize the need to promote policy directions that at least consider the relation between gender equality and taxation. Still, this does not change the fact that the power to change policy is ultimately in the hands of national states.⁶ Therefore, the discussions taking place at the international level need to trickle down to the national level in order for the objective of gender equality to be realized.

This article tackles the complexity of both new and old societal challenges to the realization of gender equality obligations through tax provisions and tax policies at the national level. As these judicial issues are highly country-specific, we have chosen to compare Denmark and Sweden to illustrate ongoing challenges and the differing ways in which individual countries may choose to tackle them. Both Sweden and Denmark have historical roots in the formation of the so-called Nordic welfare state model based on egalitarian and communitarian ideas.

Alarmed by the message from the U.N. secretary-general, we address the following questions in particular: Is the women-friendliness of our welfare states put at risk because of the recovery programs? Will the emerging regulatory responses on the EU and national levels to collapsed economic activities and fragmented economies, in the form of state aid actions that cover both tax and social welfare regulations, lead to a loss of headway and an increase in inequalities between men and women?

Throughout this article, we argue that the financial recovery needs to include a human rights perspective on tax justice that concentrates on the realization of right through efforts such as resource mobilization, redistribution, regulation, representation, and accountability.⁷ Our hope is that in times of crisis, an opportunity for reconsiderations will open, and that the fact that the world needs strong, well-targeted fiscal support to recover can help pave the way for new tax policy directions.⁸

I. Gender Equality and Taxation in the EU

Gender equality is a high priority on the EU’s agenda, which can be seen in the European Commission’s work. On a continuous basis, the commission has expressed concerns about the relationship between taxation and the labor market participation of secondary earners in the member states.⁹ For instance, within the EU the majority of working women involved in relationships are secondary earners, earning on average about one-third of the couple’s joint income.¹⁰

The European Commission has identified joint taxation as one barrier to the equal participation of women in the labor market.¹¹ As a result, active tax policies are needed to better use female talent and to improve the participation of women in the European labor market, their economic independence, and their pay and pensions.¹² However, any such ambition needs to be linked to the overall design of national tax systems, and especially the prioritization of the secondary earner.

A major hindrance to the realization of these ambitions is that the joint taxation of the family, extended households, and spouses has very strong cultural roots. Jointness in income taxation has supported the single-breadwinner family model through joint filing; allowing the splitting of household income; and the transferability of income allowances, basic deductions, and loss reliefs between spouses. Joint taxation is also connected to an old tax theory debate occupied with the question of taxability.¹³

In the EU, the number of countries that apply a conventional joint taxation model is decreasing. However, many of the joint elements in the tax-transfer interface remain in most countries. One of the few exceptions is Sweden, which introduced individual income taxation for earned income in 1971 in a way that has proved to be sustainable in terms of gender equality.¹⁴

Replacing the income-splitting system with individual taxation would markedly increase female employment. Eliminating tax-related disincentives to female employment and the unequal distribution of paid and unpaid work is one of the most critical objectives of tax policy.¹⁵ This is why the European Parliament’s demand that the EU member states phase in full individual taxation, including the elimination of tax expenditures and benefits based on joint income, is an important step forward.¹⁶

II. The Nordic Context

A. General Overview

The Nordic countries share characteristics commonly associated with having comprehensive social safety nets, including public services that are provided through a largely tax-funded system; relatively high tax burdens; public pension plans; a high percentage of workers belonging to a labor union; and the existence of partnerships between employers, trade unions, and the government.¹⁷ The Nordic welfare state model is renowned for being women-friendly because they promote substantive, structural gender equality in legal provisions and have extensive welfare programs.¹⁸

Yearly reports on gender gaps from the World Economic Forum place the Nordic countries of Iceland, Sweden, Finland, and Norway in the top five countries with the highest degree of gender parity, while Denmark has lost its place among the top 10 during recent years and now finds itself in 14th place.¹⁹ It is fair to state that the Nordic countries have managed to build a sustainable economic and political structure for gender equality based on information on national gender gaps in economic, political, education, and health arenas. Another possible conclusion is that reforms aimed at improving the participation rate of women in the labor force are essential. This includes the recognition that welfare reform efforts need to concentrate on improving the ability of both parents to balance work and family.²⁰

Furthermore, economic gender equality problems have been linked to the divide between the public sphere of markets and politics and the private, domestic sphere of care and household work. This division affects the equality of opportunity, which is a basic prerequisite for social justice. Historically and globally, women’s lives have been centered in the private sphere, which cements their subordinated economic position in society, leading to gendered inequalities.

In contrast, tax systems and tax policies are normally built on the assumption that society is gender-neutral, and they do not recognize the structural discrimination against women that resides in the socioeconomic differences between men and women. For instance, women work part time to a greater extent, are more likely to take parental leave, and devote more time to caring for children. Women also live longer lives and are often younger than their partners in couple relationships. This results in the promotion of male norms despite the system and the policies being formally gender-neutral.²¹

During the first decade of the 21st century, Nordic welfare states underwent a transformation in many areas, and existing welfare institutions, regulations, and policies were replaced by market-oriented neoliberal frameworks. The neoliberal influences on the so-called Nordic model have also had an impact on the boundaries of the public-private divide, which were changed by political as well as market initiatives.

Finally, family taxation is a field that has an obvious connection to gender equality, even though it is seldom officially recognized. Joint tax provisions in family-based income tax systems are among the tax provisions with the most immediate and obvious gender implications, including both allocative and distributional outcomes. They are formally sex-neutral, but in practice they touch upon the intersections between gender, tax policy, and the law. Joint tax measures create disincentives for labor market participation and reduce the number of hours that secondary earners work.²² The two cases of Sweden and Denmark efficiently illustrate how the choice between joint taxation and individual taxation may affect gender equality in various spheres.

B. The Swedish System

A prominent characteristic of the Swedish welfare state is that gender equality policies have historically been closely intertwined with the welfare state ideology. In the formation of the welfare state, gender equality has been a major concern taken into account in many welfare reforms, particularly those involving the labor market. The Swedish social democratic welfare state has promoted a socially egalitarian environment that values solidarity and redistributive social justice. Social entitlements are based on various eligibility criteria, with residence-based eligibility being the element that veers the closest to an inclusive, universal regime. Social security rights are largely based on work performance but supplemented by safeguards based on Swedish residence; thus, a portion of benefits is differentiated on the basis of wages from labor market participation. This dominant egalitarian workfare idea has governed women’s social, economic, and political rights.

Even though the workfare concept leaves many issues of gender equality found in the private sphere of society outside the scope of political reforms, tax and social security law are among the most powerful tools for breaking down barriers between the public and private spheres of welfare economies. An analysis cannot be limited to the income side of the public budget if the full breadth of women’s economic subordination is to be grasped. The structures of revenue and social transfer programs are intertwined in welfare state policies.²³ The interplay and interdependence of revenues and expenditures in public budgets is an important issue discussed by gender budgeting scholars; it is important to consider this relationship when studying tax policies and how they influence gender equality, including in the Nordic welfare states. The Swedish experience shows that the interplay between taxes and social transfers in the public budget can be used to equalize disposable incomes between men and women.²⁴ From a gender equality viewpoint, tax and social security regulations mirror what the state views as the preferred way of organizing families, the difference between productive work in the market and unpaid care work in the home, and judgments about which social spheres of work should be predominantly male and female.²⁵

There have been four major phases in Swedish tax reform, which sometimes include its interaction with social security law, that not only reflect, but also helped change the dividing line between the household-based care economy and market economy, thus producing a more equitable work-life balance for men and women. These phases were marked by the following:

• the individual tax reform of 1971;

• the fiscal, marginal income tax reform of 1991;

• the incompatibility of income taxes and social benefits that led to inequality and poverty traps for, in particular, single mothers during the 1990s; and

• the introduction of earned income tax credits and tax credits for domestic work in 2007.²⁶

Sweden employs individual taxation and not joint taxation, resulting in spouses being taxed and receiving public benefits on an individual basis. There are merely a few exceptions to autonomy in the Swedish independent tax and social security system, which include a household-based income calculation of fees for public daycare facilities and a part of the housing benefit.

Swedish taxes are not earmarked, resulting in a weak link between actual tax payment and eligibility for receiving public benefits. Social insurance law — that is, rules on the distribution of public benefits — is therefore an essential element of Swedish gender tax policy because many public benefits are designed with the intention of facilitating and increasing female participation in the workforce and labor market.

The Swedish Social Insurance Code (SIC) applies two criteria²⁷ when granting access to public benefits:

The first criterion grants access to work-based benefits — such as sickness allowance, income-based pension, and occupational injury compensation — to those who have Swedish employment and pay taxes on employment income in addition to the corresponding payroll taxes paid by the employer, which is currently 19.8 percent of the employee’s gross salary.²⁹ It is worth noting that there is no requirement that the individual actually paid taxes; it is sufficient that the individual shows it is likely that he or she had an income on which one can presume that income and payroll taxes were paid. The simplest way to fulfill this requirement would be to look at the individual’s declared income, which is easily done using Sweden’s system of civic personal identification numbers. The individual is therefore assumed to contribute with taxes (income and payroll) through full-time employment in order to fulfill his or her part of the social contract while the Swedish state, in return, agrees to support the individual through public benefits when so needed.³⁰

The first criterion is considered inadequate from a gender perspective because, in practice, it generally excludes fewer men than women. This is because more men than women work full time. This shortcoming has been acknowledged, and Sweden therefore applies a second criterion as a safeguard that primarily targets women.³¹

Therefore, residence-based benefits safeguard both women who work part-time jobs and women in stay-at-home roles — even if the latter are rare in the Swedish system. These benefits are arguably family friendly by nature as they comprise parental allowance, child benefits, and a guaranteed pension — ensuring that women will have a pension, even if they have not been able to work full time or have not worked outside the home at all — and are awarded in accordance with territorial affiliation rather than economic activity.

One residence-based benefit is reduced child care costs (kindergarten and preschool). The child care fee is dependent on the number of children (that is, the rate goes down proportionally and is eliminated after the fourth child), whether the child is taken care of full time or part time, and the collected gross income of the household. The fee is considered low compared with other countries, with the minimum level being about SEK 1,000/child per month (about €100) and the fee capped at about SEK 1,500/child per month (dependent on the municipality).

To qualify for these residence-based benefits, an individual must have a permanent domicile in a Swedish municipality. This criterion bears a resemblance to the Swedish fiscal residence criterion³² — it is determined with reference to the individual being registered in a Swedish municipality, regardless of whether it is the individual’s primary residence.³³ As a result, accessing residence-based benefits is straightforward for a Swedish citizen. However, according to chapter 5, section 3 of the SIC, a foreigner who has relocated to Sweden must remain in Sweden for at least a year to fulfill the domicile criterion.

C. The Danish System

Denmark’s system contains stronger elements of joint taxation compared with Sweden’s. Historically, Denmark taxed the husband for all income that originated from the family, including incomes from the wife and children.³⁴ This practice was finally abandoned in 1982.³⁵ However, there are still some remnants of the former system, such as joint taxation of some capital and business incomes and having parents assume the tax burden for children under 18 years of age.

Denmark justifies these remnants of joint taxation as a way to support married couples in which only one spouse works and to prevent tax planning schemes between the spouses.³⁶ The beneficial tax treatment that applies to married couples does not apply to partners in common-law marriages or unmarried couples who cohabitate. Sweden does not make such a distinction — partners are subject to the same rules and protection regardless of whether their relationship has been formalized through marriage.³⁷ Instead, Sweden only considers whether a couple is cohabitating as a result of a romantic relationship.

There are also differences in the two systems for payments to support public benefits. While Sweden primarily relies on income and payroll taxation, Denmark uses a labor market contribution fee (AM bidrag), which, unlike its Swedish equivalent, burdens the individual and not the employer.³⁸ As a result, a Danish employee is not only taxed on income, but also liable to pay a social insurance contribution (currently 8 percent). The contribution applies to anyone who is liable for Danish income taxation, regardless of whether the person in question is subject to full or limited taxation or whether the income is the household’s primary income or a supplementary source of income. Also, the contribution applies to parental leave income, pension payments, and unemployment incomes because these forms of income are considered to originate from employment. Tax-free incomes are exempted, illustrating a partial link between the tax system and the social insurance system.

Furthermore, the same principles used to grant access to public benefits in Sweden apply to the Danish system. In other words, payment of the AM bidrag and Danish residence (territoriality) are used as qualifying requirements for receiving social benefits. Unlike in Sweden, the cost of child care is neither standardized nor capped. Therefore, fees for Danish child care may differ slightly between municipalities and are considerably higher than in Sweden. In general, the municipality pays about 75 percent of child care costs, which means that the parents account for the residual amount. Low-income earners can apply for additional financial support from the municipality to reduce their cost, and in some cases the municipality covers 100 percent of the child care costs.

Sweden applies higher social security contributions than Denmark and burdens the employer instead of the individual taxpayer. Danish social security contributions are almost half of the Swedish burden, and the individual pays the fee.

The differences in social insurance burdens trickle down to the public benefits systems. The Swedish system is more generous. For example, child care costs are lower and public pensions are more comprehensive — as noted, largely to safeguard women, Sweden even awards minimum pensions to individuals who have not worked or worked part time.

The Danish system, on the other hand, is based on the taxpayer either assuming responsibility for most benefits or negotiating benefits as part of their employment contract. The level of sick pay, pension payments, and maternity leave is often dependent on the employment contract in question rather than social insurance coverage, leaving low-income workers — primarily women — more vulnerable. This is may be one reason why the Danish system still applies some elements of joint taxation since these elements arguably act as a safeguard for women.

III. COVID-19 and Gender Equality

Comparing Sweden and Denmark is interesting because they have taken very different approaches to the pandemic despite being closely connected in both geography and law.³⁹ Denmark was among the first countries to close both its borders and its society, with the government implementing far-reaching protocols on social distancing. Meanwhile, Sweden left its borders open and relied on its citizens to assume responsibility for limiting transmission of the coronavirus rather than enforcing state regulation. Sweden’s (at least superficially) lenient response has been widely debated internationally. The two states have also reacted differently in terms of financial support measures, in part because of their conflicting approaches to social distancing.

Denmark quickly implemented several state aid packages aimed at compensating workers for lost income and businesses for lost profits. Various stimulus checks have also been discussed and implemented to support specific groups more extensively. For example, last summer Denmark’s government distributed stimulus checks to those who had worked during the previous year and earned vacation days. The size of these checks was based on salary and vacation days earned (the higher salary, the higher compensation per vacation day), thus making the payments completely dependent on income level and benefiting full-time high-income earners, who are predominantly men. These stimulus checks will be paid out again in April.⁴⁰

Even though both Denmark and Sweden have infused the dual-earner family model into their tax systems, men are still the breadwinners in most families with children, particularly when the children are young. Frequently, men work full time while women are secondary earners with lower salaries and often work part time.

This inequality is aggravated in times of crisis, when the family may be forced to decide who stays at home and who works. This has become particularly noticeable in Denmark because child care centers and educational systems have been closed for longer periods. Sweden, on the other hand, has chosen to keep child care facilities open because of its more relaxed COVID-19 strategy.

When combating this situation, the tax-transfer system will have greater influence in countries that have taken an approach like Denmark’s. Different features of the tax-transfer system will influence how parents divide the responsibility for caring for children at home. Taxing families as a unit rather than as individuals incentivizes families to have a full-time stay-at-home parent — typically the woman — because they would pay higher taxes if the second spouse started working part-time. This is not just because the income rises but also because they would no longer qualify for some tax deductions that are based on the presence of a stay-at-home partner. Shifting to a system that taxes individuals rather than family units (and one that offers child care benefits) eliminates these barriers to workforce entry.

Furthermore, both Sweden and Denmark have, like most European countries, chosen to allocate nearly all their pandemic-related financial aid to the corporate sector⁴¹ rather than individuals and families. Common corporate state aid measures include:

• compensation to companies for their fixed costs;

• reimbursement for lost profits;

• for some companies, the option to have VAT and salary fees refunded as interest-free public loans; and

• state guarantees and credit loans.

The decision to focus direct financial aid packages and tax policies on the corporate sector is particularly notable because COVID-19 has further aggravated gender inequality. This is a lost opportunity; this would have been an ideal time to implement new tax policies that would have been politically difficult to enforce in other environments. The debate on wealth taxation, which has been driven by the pandemic’s revelation of socioeconomic inequality, is a good example of such a tax policy opportunity.

IV. Tax Policy Proposals

The authors believe that several interesting and beneficial tax policies could be implemented as part of the response to the pandemic that could strengthen gender equality in both the short term and the long term.

Initially, individual countries should consider targeting business sectors that are mainly occupied by women and that have been hit hard by the pandemic, such as healthcare, education, and the service sector. Designing financial aid measures in such a manner would not actively differentiate between women and men — which would be considered discriminatory in some legal systems — while still supporting female-dominated sectors that have, so far, received less financial support than others.

Moreover, issuing checks devoted to child care would provide families — mothers in particular, since they are likely to be the primary caregiver when children stay at home — with much-needed relief. This would not only help women to maintain their jobs — whether they are working from home or at their usual workplace — because it means they would not need to focus on child care, but it would also support the child care sector, which is dominated by female employees and female business owners. Means-tested cash transfers would also be useful in this context because they would allow parents to return to work by enabling them to hire private child care, such as babysitters or other paid child care. Home-based child care subsidies would be an option when it is not possible to have child care outside of the home because of virus-related restrictions. When designing state aid measures, states will need to figure out ways to ensure that these checks are not misused for other purposes, which is often the case with such tax measures.

Stimulus checks could also be issued (with salary caps). This would result in financial support being given to those with the greatest financial need and those who are in the most vulnerable jobs. Statistically, women report less income than men as a result of both part-time work and lower-income jobs, making them primary recipients of such a stimulus check.

In this context, the authors would like to emphasize that the practice of using tax payment as a requirement for financial COVID-19 aid is unsatisfactory when applied to individuals.⁴² Those in the greatest need — that is, the unemployed, students, pensioners, unreported workers, part-time workers, and so forth — are left out and denied critical support. One way to resolve this would be to implement jobless subsidies based on alternative criteria such as citizenship or residence. The latter would be the better option if comprehensive inclusion is the goal. This reasoning resembles the previous discussion on social benefit safeguards, which are inherent to the Nordic welfare states.

Finally, proposed tax policy measures should be administered through tax administrations to accelerate and centralize aid-related processes. The use of civic identification numbers in Sweden and Denmark is designed with this purpose in mind — not only does it ensure transparency and efficiency, but it also acts as a safeguard against misuse and fraud.

V. Conclusion

It is important to acknowledge that supporting women automatically results in supporting children’s development, especially during the pandemic, when most EU member states — including Denmark (but not Sweden) — have closed their educational systems and child care centers to contain the spread. Further, research from the U.K. Women’s Budget Group shows that a public investment in care for both children and adults in the United Kingdom would yield 2.7 times as many jobs as an equivalent investment in construction (6.3 times as many jobs for women and 10 percent more for men).⁴³

In times of crisis, opportunities for reconsideration open. The fact that the world needs strong, well-targeted fiscal support to recover can make new policy directions possible.⁴⁴ A consolidated concept of a fair and sustainable tax base is key to enabling economic recovery after the pandemic. Although this is not a new argument, the taxing-for-growth policy agenda has governed national tax reforms and dominated international tax policy discourse for decades — and it has been contradictory to the ambitions we discuss in this article. The tax policy agenda has created a multitude of sustainability and inequality issues that ultimately contradict the goal of advancing the financial recovery from the pandemic in all societies around the globe, irrespective of whether they are low- or high-income countries.