KEY POINTS:
Democracies around the world are wrestling with the problem of election funding, says Otago University election law expert Andrew Geddis. "Political parties have to have money to do their job, and in an ideal world they'd have large party bases to fund them. Unfortunately, mass membership of political parties is dwindling worldwide, which means that they have become more and more reliant on small groups of donors who give money and may seek influence on those parties."
Solutions being suggested here include severely restricting private donations from both individuals and organisations, insisting on the disclosure of the identity of all donors - including those giving only small amounts - the curtailment of third-party campaigning by organisations such as the Exclusive Brethren, and more state funding.
After serious funding scandals in 1990-2000, Canada brought in extensive reforms which will come into play during their next federal election, probably in 2011. The aim is to achieve transparency, equality - and rule out large contributions and therefore possible influence from pressure groups or wealthy financial interests.
Says Geddis: "They've set the limit low enough to encourage lots of people to contribute - and force the parties into grass-roots fundraising."
A similarly radical approach is being debated in Britain. If adopted, the new system would limit private donations to £50,000 ($134,700), rather than the limitless freedom they enjoy now, and the Government would provide funding of 50p each year for every vote obtained in the previous election to keep the parties afloat.
The question, says Geddis, is whether that method of funding would mean political parties become just another branch of the state.
Canada
* Only individuals (citizens or permanent residents) may give money. No company, trade union, pressure group donations.
* Individuals may donate up to C$1100 ($1321) a year to each registered political party plus C$1100 per year to the various entities of each political party (registered associations, nomination contestants and candidates). Plus no more than C$1100 per year to each candidate.
All donations are partially tax deductible.
* No anonymous cash donations above C$20 are allowed and all donations of more than C$200 must be reported.
* State funding: Private donations are supplemented by public funding at the rate of $C1.75 per vote gained in the previous election. This is paid quarterly (only parties that gained over 2 per cent of the national vote are eligible). Fifty per cent of political parties' and candidates' election expenses are reimbursed.
* Spending limits: Party election spending is set at C70c per voter and covers all associated election spending, including focus group research, opinion polling, consultants, travel, advertising, pamphlets etc.
* Election spending is limited to the period between an election being called and the polling date, which can be as short at 26 days.
* Third-party campaigning: Spending limits extend to advertising on issues surrounding an election - for example, the anti-fart tax campaign. Although these can be placed by pressure groups, unions etc, spending limits for such advertising by outsiders is set at C$179,400 (about the same as the cost of a full-page ad in the country's major daily newspaper).
* Disclosure: From January 1, 2005, parties have been required to submit a quarterly report detailing contributions and transfers.
Australia
* Individuals and groups can donate as much as they want.
* Public funding: Funding is calculated by multiplying first preference votes by a funding rate which relates to the Consumer Price Index (calculated six monthly). In 2001 (latest figures available) public funding totalled A$38,559,409.33 ($43,671,319.28) .
* Spending limits: Parties are not required to disclose what they spend and there are no restrictions on buying TV time.
* Third-party campaigning: Donor organisations, such as the Business Roundtable and trade unions, which spend more than A$10,000 on political support, must disclose funding sources and also register with the Australian Electoral Commission.
* Disclosure: Individuals and companies, trade unions, pressure groups must disclose all donations over $A10,000. Receiving parties and associated entities must supply total receipts and details of amounts of A$10,000 or more and candidates must disclose contributions over A$10,000.
United States
* The bulk of funding is based on private individual donations of up to US$4000 ($5447) to chosen candidates. Often high-profile people, for example movie stars with many wealthy friends, gather US$4000 donations together and present them in a single, big bash, extravaganza.
This is particularly popular with presidential candidates who use the system to demonstrate how popular they are with grass-roots supporters by drawing in huge amounts of cash: the more money you can raise the more popular you are. This system was demonstrated last week when Senator John McCain was judged a dismal failure as presidential candidate by this measure alone.
* Public funding: Although there is a system for public funding, candidates have to agree to limit their spending in order to qualify for it. In practice few bother.
* Disclosure: Although funding is limitless, all party donations over US$200 must be disclosed, and although individuals can donate to candidates, companies and trade unions cannot do so directly.
United Kingdom
* No limits on giving, though donors have to be either British residents, or British companies, trade unions or societies.
* Public funding: No direct funding.
* Spending limits: £20 million ($53.9 million) per party: covers year before election and all election-related expenses including consultants, polls, travel, focus groups etc.
* Disclosure: No trust giving is allowed. All donations over £100 must be identified. Once an election is called all donations over £5000 must be disclosed.
* Third-party campaigning: Individuals or groups can spend up to £1 million in the year prior to an election.
Norway
* Spending limits: None.
* Income limits: None. Anonymous donations from corporates, trade unions, government contractors, and foreigners are accepted.
* Public funding: Yes, related to share of vote in previous election plus free media/broadcast time.
* Disclosure: Individuals and organisations do not have to disclose donations but political parties must disclose all donations over NOK20,000 or $45,428.
