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Who Opts Out? The Customisation of Marriage in the German Matrimonial Property Regime [PDF]
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
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]
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
Matrimonial Property Regimes: Yesterday, Today and Tomorrow
H. R. Hahlo
doaj +4 more sources
APPLICABLE LAW IN MATRIMONIAL PROPERTY REGIME DISPUTES
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]
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]
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
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?
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
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

