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Charlotte Butruille-Cardew, Avocat a la Cour d'Appel de Paris. The French rules governing marriage and divorce are different to those in operation in the UK. In this article the author examines the concept and workings of the French matrimonial regime, with a specific focus on the several regimes applying to matrimonial property. The focus then turns to the status of pre-nuptial agreements in France with an analysis of the applicable rules. Where international marriages are concerned there are also rules governing their status and that of any pre-nuptial agreement. The difficulties in ascertaining the form, authority of and conditions for the validity of pre-nuptial agreements across European Member States provoked the European Commission's 2006 Green Paper on matrimonial property rights. Essential differences exist between the common law systems and civil systems of different European countries and it remains to be seen whether the Green Paper proposals can integrate these. For the full article see June  International Family Law.
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