Study on matrimonial property regimes and the property of unmarried couples in private international law and internal law

This is the National Report on German Law regarding property relations in social unions, like marriage, other legally acknowledged unions, and de-facto unions. It covers heterosexual and same-sex unions. Although the special focus of the report is on international relations (international jurisdiction and recognition of foreign acts; private international law), the substantive law of matrimonial property and property relations in similar unions will be discussed, too, in order to give a better understanding of the rules and problems of German law in the international context. This will also facilitate the comparison between different national laws in Europe, and allow the identification of common problems as well as national peculiarities. It will be shown that the changes that were caused by the rise of the principle of equality between husband and wife are nearly completed now, while new problems are caused by the rise and legal acceptance or even regulation of non-marital unions. The legal developments in other countries will be taken into account insofar as they may affect the operation of German private international law. In writing the report, the authors have followed by and large the Questionnaire.