The Hague Convention of 14 March 1978 on the law applicable to Matrimonial Property Regimes (HCCH25) entered into force on 1 November 1992 having been ratified by France, Luxembourg and the Netherlands (the HCCH25 States).
EU Regulation 2016/1103 of 24 June 2016, implementing enhanced cooperation in the area of jurisdiction, applicable law and the recognition and enforcement of decisions in matters of matrimonial property regimes (EU MPR), came into full effect on 29 January 2019.
Russell-Cooke consultant Richard Frimston dives into where these two regimes intersect, overlap and clash in their application to matrimonial law.
'Where Does the Hague Stop and Brussels Begin?: The Interplay of HCCH 25 and EU Regulation 2016/1103' is available to read in Private Client Business via subscription.
Richard is a consultant in the private client team.
He advises clients in relation to their estate planning, wills, probate and tax planning issues and offers Notary Public services. Areas of expertise include cross-border estates and international private law issues.