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Today there are no common international rules as to which state's
law shall be applied when a married couple have connections with
more than one state e.g. British citizens living in France. Each
state has its own so called private international law rules (PIL),
leading to conflicts of laws. There are no common rules as to which
court has jurisdiction and Court decisions are normally not
recognized in other states. Since, today millions of people live in
a state other than their state of citizenship or have assets in
states other than where they are living, the EU has seen the urgent
need for an EU-Regulation on matrimonial property and a parallel
Regulation for registered partners. The Regulation does not provide
any common material matrimonial law in the EU, but common PIL that
sets out which state's matrimonial law shall be applied, which
state's court shall have jurisdiction and that court decisions in
one state shall be recognized and enforceable in other EU states.
This volume is an article-by-article commentary on the Regulations
which have been adopted by the EU Council on June 24th 2016 and
will come into force on January 29th 2019.
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