Couples in Europe - Matrimonial and Registered Partnership Regimes National law of 33 European countries


Couples in Europe - Matrimonial and Registered Partnership Regimes National law of 33 European countries


Knowledge of foreign law on proprietary relationships between spouses and registered partners, especially after the adoption of the  two EU regulations (2016/1103 and 2016/1104), remains of particular interest to legal practitioners (be they judges, notaries or lawyers), as they may often be called upon to handle spouses’ and partners’ property cases that have cross-border effects.

However, in this modern era, with so many international couples who move around and conduct business in more than one countries, even private citizens might well take an interest in learning about the laws of other countries, so that they are informed and able to better arrange the legal status of their property relationship with their spouse or partner, as well as arrange succession matters, taken into account that the respective provisions of property relationship and succession are closely connected.

This publication serves as a valuable reference in this sector, as it constitutes a practical guide to the current applicable laws in thirty three (33) European countries on matters that relate to property rights of spouses and partners, such as the conditions of validity for marriage and for registered partnership, the basic matrimonial and partnership regimes established by law in each country, and the possibilities that each national legislature has conferred with regard to choosing a property regime different from the one in place. 

This collection of reports also covers the assets that constitute common or personal property of a couple, and common and personal debts. In addition, it addresses the property effects of the default legal matrimonial regime and those of matrimonial agreements between spouses and partnership agreements between partners, as well as between the couple and third parties. It further contains information on the conditions for transferring assets (especially immovable property) that belong to one or both partners or spouses. 

Moreover, this collection explores the powers of each spouse or partner regarding assets, the conditions of validity for matrimonial and partnership agreements, the publicity of any chosen regime, the existence or absence of an inventory of assets, and the rules of private international law that govern property relations, including the right of professio juris, and other issues. 

The thirty three (33) countries that participate in this publication are: Austria, Belarus, Belgium, Bosnia and Herzegovina, Bulgaria, the Czech Republic, Croatia, Cyprus, Estonia, France, Georgia, Germany, Greece, Hungary, Italy, Kosovo, Latvia, Lithuania, Luxembourg, Montenegro, North Macedonia, Poland, the Principality of Andorra, Romania, Russia, Serbia, Slovakia, Slovenia, Spain, Switzerland, Turkey, Ukraine,  the United Kingdom.

This edition includes the reports in English or in French, depending on the language choice each country’s reporter has made. Thus, twenty-seven (27) countries present their legislation in English, while six (6) do so in French. The reports in French are accompanied by summaries in English. 

This edition is the result of the collaboration of three European notarial institutions CAE - IRENE – CNUE.  

The coordinator of the project is Marianna Papakyriakou, notary in Greece, Vice-President of CAE.

You can buy the publication here


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