The object of this report is to present an outline on the central features of the private international law rules relating to matrimonial property in England and Wales. In the United Kingdom there are several distinct legal systems: England and Wales, (one legal territory, referred to hereafter simply as England), Scotland, Northern Island and the Channel Islands. While the laws of Northern Island and the Channel Islands are basically not dissimilar from English law, the law of Scotland is markedly different. This report only covers the laws of England.
The report follows the general scheme suggested in the directions to National Experts. However, as there are no primary and secondary property regimes in England, some adaptation of the suggested scheme has been necessary.