Blog
Rayner my parade! The importance of specialist advice.
Jemma Brimblecombe
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.
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.
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.
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.
4 April 2024
French matrimonial regimes: the wide ranging impact for couples with Anglo-French connections
The concept of matrimonial regimes has become increasingly well known in England, having been a stalwart of the French marriage process for centuries. International clients and those with Anglo French connections are asking the right questions about French marriage contracts versus English prenuptial or postnuptial agreements more frequently, being more aware of the significant differences between the two and also the need for cross-border legal advice to ensure their interests are protected should they later choose to divorce.