Legal Certainty in Determining the Matrimonial Property Regime in Cross-border Situations (changes of habitual residence and acquisition of real estate property abroad)
The application of different conflict-of-law rules depending on the competent jurisdiction may lead to divergent outcomes regarding the matrimonial property regime in cases involving real estate property investments abroad or changes of habitual residence. In this context, a preventive approach combining matrimonial property regime agreements with a choice-of-law clause (typical of Civil Law systems) and […]
