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Anglo French Family Law

26 February 2025

French marriage contracts in England – are we finally aligned across the channel?

The English Channel, La Manche, is only 350 miles long, separating England from France.  When looking at divorce principles however, we have historically been oceans apart from France, with significant differences in outcome depending whether the proceedings have taken place in France or in England.  French law is based on a civil code, with divorce law applying property regimes to the division of assets, which is often incompatible with the common law, discretionary system in England.  In the early years of my Anglo-French practice, French couples living in England were often taken aback to learn that the property regime they chose when they signed their French marriage contract might not be applied by English judges if they divorced in England.

Claire Wood

6 February 2025

Filing for a "Eurostar" divorce - Paris or London?

London has long been a popular city for French expats, and despite the reported drop post- Brexit, is still home to a reported 100,000 French nationals many of whom applied for settled status. There are 9 bilingual French schools in London and with the Eurotunnel celebrating 30 years of operation, London remains an attractive residence for French professionals.

Claire Wood

30 January 2025

Anglo French prenuptial agreements – the myths of cross channel protection and the global prenup?

I am regularly asked to advise French and international couples on the protective agreements available to them before they marry.  They are often surprised to learn that it isn’t possible to draft a global prenuptial agreement which would be enforceable throughout the world, wherever the couple move to in the future.  

Claire Wood

21 May 2024

Les conséquences involontaires du PACS – attention au piège

Le Pacte Civil de Solidarité (PACS) est un contrat conclu entre deux adultes non mariées, de même sexe ou de sexe opposé, qui leur permet d'organiser leur vie commune. L'enregistrement de l'union civile entre les conjoints se fait à la mairie. Le contrat de PACS peut également être rédigé par un notaire afin que les clauses de leur contrat soient adaptées à leur situation familiale et financière.

Claire Wood (Français)

16 April 2024

Till death us do part – matrimonial regimes, nuptial agreements and inheritance

The importance of inheritance planning cannot be underestimated – failure to consider the succession and tax consequences that arise on the death of a spouse can lead to significant financial implications, at a time when emotions could already be running at an all-time high. Particularly in situations where there is a large amount of familial wealth, the earlier this is considered, the better, and marriage (and the election or not of a matrimonial regime, or creation of a bespoke nuptial agreement) is a good time to take stock and ensure your family is protected for the future.

Sophie Voelcker

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