Matrimonial property regimes and patrimonial aspects of other forms of union: what problems and proposed solutions? (Proposal for Rome IV Regulation)

30-11-2010

This note provides an objective analysis of the property law aspects of living together in situations where the relationship has connections with more than one EU Member State. The analysis focuses on couples, whether opposite-sex or same-sex relationships, living together either in the form of a marriage, a registered partnership or who de facto live together. The note identifies main problems related to the matrimonial property regimes and patrimonial aspects of other forms of union with a cross-border dimension and concludes by making some recommendations.

This note provides an objective analysis of the property law aspects of living together in situations where the relationship has connections with more than one EU Member State. The analysis focuses on couples, whether opposite-sex or same-sex relationships, living together either in the form of a marriage, a registered partnership or who de facto live together. The note identifies main problems related to the matrimonial property regimes and patrimonial aspects of other forms of union with a cross-border dimension and concludes by making some recommendations.

Εξωτερικός συντάκτης

Sjef van Erp, Professor für Zivilrecht und Europäisches Privatrecht, Institut für Europäisches Privatrecht, Universität Maastricht