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.
Ulf Berquist, Domenico Damascelli, Richard Frimston, Paul Lagarde, Barbara Reinhartz