• 1. Introduction to the Research Study
  • Basis of the research study<br< Approaching and selecting respondents
  • The interviews
  • 2. Responses to the Questionnaire
  • A. General questions
  • B. Possible advantages of harmonisation
  • The phenomenon of forum shopping
  • Measures to counter forum shopping
  • Lex fori as a solution to forum shopping
  • Legal certainty and predictability of result
  • Free movement of persons and the smooth functioning of the internal market
  • C. Possible effects of harmonisation
  • Increase and complication of proceedings
  • Effects on agreement between the parties and out of court settlement
  • The extent to which all related matters can be dealt with in the same proceedings, and applying the same law
  • D. Possible impediments and disadvantages
  • Other remarks
  • 3. Main problems that were identified during the interviews
  • Divorce
  • Application of choice of law rules
  • The influence of internal substantive law
  • Forum shopping in divorce cases
  • Legal certainty, predictability of result
  • Free movement of persons
  • Parental responsibility
  • Choice of law rules
  • Forum shopping
  • Legal certainty, predictability of result
  • Free movement of persons
  • Maintenance of spouses
  • Content of choice of law rules
  • Forum shopping
  • Free movement of persons
  • Maintenance of children
  • Jurisdiction and forum shopping
  • Free movement of persons
  • Legal certainty
  • Matrimonial property
  • Forum shopping
  • Distribution of marital property
  • Free movement of persons
  • Location of assets
  • Public policy
  • Application of foreign law
  • Civil law systems v. common law systems
  • Specialization of judges and lawyers
  • Cultural differences
  • 4. A few case studies
  • Divorce
  • Case 1. The unfortunate twins
  • Case 2. Divorce at the second attempt
  • Case 3. A look in the future
  • Children
  • Case 2. The divorce motheru0092s international career
  • Matrimonial property
  • The enterprising couple<br< 5. What issues