Matrimonial Property System Comparate Research

Matrimonial property system that stipulates the matrimonial property relation is one of important parts of the family law. Because of some special factors, such as history, economy, civilization, tradition, and custom, different countries have different matrimonial property system. This thesis makes a comparison of matrimonial property system among the countries, which belongs to the Continental Law System or the Anglo-American Law System, and induces the tendencies of matrimonial property system in the world. After pointing out the defects in the matrimonial property system of China, the author proposes the advice to prefect itThis essay is composed of four parts excluding the Foreword and the After-word.Part One: An introduction to matrimonial property system of foreign countries. The author textually introduces the legislative stipulation about matrimonial property relation in eight countries, including France, Germany, Switzerland, Russia, Japan, Italy, the United Kingdom England and the United States of America.Part Two: A comparative study on matrimonial property system of foreign countries. After discussing the similarities and differences of matrimonial property system in the countries, the author puts forward her ideas and main reasons.Part Three: The tendencies of the matrimonial property system in the world. On the basis of comparative study, the author induces four tendencies of the matrimonial property system in the world. Additionally, the author demonstrates the necessity and reasonableness that the tendencies are formed.Part Four: The study on consummating the matrimonial property system in China. The author points out the defects in our matrimonial property system that involve structure of legislation, general rules, contractual property system and legal property system. Simultaneously, the author expresses her suggestion to prefect the matrimonial property system.