English Law, international jurisdiction and Law applicable to the matrimonial property regime

Abstract

One of the great differences between English Law and Spanish Law is found in matters of matrimonial property regime; Thus, in the first one, it is based on the non-existence of said institution. However, English Law does regulate the economic effects of marriage in the event of divorce. All of this gives rise to the fact that in cases of international marriage crisis with Spanish and British interests present, the spouses may have a special interest in litigating before the English courts or, where appropriate, before the Spanish courts, knowing the advantages and disadvantages that doing so may entail for one or the other, and this especially considering the possible applicable law. In this work we point out some keys to consider in these cases.