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Who Opts Out? The Customisation of Marriage in the German Matrimonial Property Regime [PDF]

open access: yesEuropean Journal of Population, 2022
AbstractThis study examines the prevalence of marital contracts across marriage cohorts (1990–2019) in Germany. We further investigate the characteristics of spouses who signed a marital contract. Using cross-sectional data from the German Family Panel (pairfam, 2018/19), we employ complementary log–log and multinomial logistic regression models to ...
Theresa Nutz, Philipp M Lersch
exaly   +7 more sources

Prenuptial agreements and matrimonial property regimes in France, 1855–2010

open access: yesExplorations in Economic History, 2018
Abstract Using both administrative and survey data, we construct new series on prenuptial agreements and matrimonial property regimes in France from 1855 to 2010. Their evolution is far from linear: approximately 40% of newlywed couples signed a prenuptial agreement in 1855, but this share dropped to less than 10% after the reform of marital property
Nicolas Frémeaux, Marion Leturcq
exaly   +4 more sources

Determining the Applicable Law in Matrimonial Property Regimes [PDF]

open access: yesThe Rabel Journal of Comparative and International Private Law
Wishing to remain faithful to the alleged principle of immutability of the law governing matrimonial property regimes, the literature interprets Art. 26 para. 1 Regulation (EU) No 2016/1103 such that if the spouses have their habitual residence in different States at the time of marriage, it is necessary to wait for a period of time to ascertain ...
Damascelli, Domenico
exaly   +3 more sources

APPLICABLE LAW IN MATRIMONIAL PROPERTY REGIME DISPUTES

open access: yesZbornik Pravnog Fakulteta Sveučilišta u Rijeci, 2019
The paper presents the regulation of the applicable law as determined in Council Regulation (EU) 2016/1103 of 24 June 2016 implementing enhanced cooperation in the area of jurisdiction, applicable law and the recognition and enforcement of decisions in ...
Neža Pogorelčnik Vogrinc
doaj   +3 more sources

The Requirements of Introducing the Common Property System to the Iranian Matrimonial Regime with a view to the Quebec Matrimonial Regime [PDF]

open access: yesJournal of Family Research, 2020
legal regimes differ in outlining the method of contribution to the household, financial maintenance, and the division of property after separation/divorce. Some legal regimes, following the CEDAW’s regime, look for an egalitarian regime which rules for similar rights and responsibilities for both parties and partial community of properties between ...
Fateme Zeynodini   +1 more
openaire   +3 more sources

Gift of professional income generated by a spouse to a third person in Mauritian Civil Law [PDF]

open access: yesAnali Pravnog Fakulteta u Beogradu, 2020
For historical reasons, Mauritian civil law has been influenced by French civil law. However, despite the differences between Mauritian civil law and French civil law and the indisputable autonomy of the Mauritian civil law, it is impossible to deny that
Georgijević Goran
doaj   +1 more source

INTERNATIONAL JURISDICTION UNDER THE EU PROPERTY REGIMES REGULATIONS – BRINGING COHERENCE INTO CROSS-BORDER COUPLES’ PROPERTY DISPUTES

open access: yesZbornik Pravnog Fakulteta Sveučilišta u Rijeci, 2021
The paper thoroughly examines the rules on jurisdiction of the Property Regimes Regulations, analysing both the expected benefits as well as the existing and potential problems in the application of the new rules.
Jerca Kramberger Škerl
doaj   +1 more source

SMART MARRIAGE CONTRACTS: THE FUTURE OF BLOCKCHAIN IN MATRIMONIAL PROPERTY LAW?

open access: yesZbornik Pravnog Fakulteta Sveučilišta u Rijeci, 2021
This paper is intended to serve as an introductory treatise on the subject of smart marriage contracts (SMC) as a manifestation of blockchain in matrimonial property law of contracts.
Ľuboslav Sisák
doaj   +1 more source

Evolving Trend of Domicile and Nationality in Private International Law with special reference to Nepal

open access: yesNepal Public Policy Review, 2022
Understanding the domicile and nationality is the key to properly adjudicating a case involving a foreign element by the judiciary. In this milieu, this paper aspires to analyse the concept of domicile and nationality with its evolving trend and evaluate
Sagar Baral
doaj   +1 more source

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