ABSTRACT
Matrimonial property law is a prime example of the internationalisation of family law. Cases often involve property or parties living in more than one jurisdiction. At the global level, the lack of legal uniformity stands out. While some patterns are discernible in the civil law jurisdictions (for example, the “community of gains” approach), this is hardly true of the common law ones. Beyond the Western world, the law is especially influenced by religious and cultural traditions. This chapter looks first at underlying concepts, introducing the main competing forces. Then it covers various systems, aspects of private international law, and developments including cross-border harmonisation.
