Study Of Comparative Law Of Matrimonial Property Regimes

Marital property system is the legal relations established between husband and wife and it is an essential component in national marriage and family law. Owing to historical, economic, cultural, traditional and other factors, matrimonial property regimes are not same in different countries. The article launches a comparative marital property system study in China, France, and Germany etc, and then compares the difference and the same. In light of China's facts and on the predecessors of research basis, the text gives some legislative proposals to perfect matrimonial property regimes. Character I includes a total of 45,000 words, except foreword and concluding remarks, divided into three parts:Part Ⅰ: The basic theory of marital property system. This part of the article firstly introduces the concept of property, character and the type of legislation, followed by an analysis of the couples property values and the origin of the introduction on three more couples property system, and then studies the overall system of property couples basic theory for the latter part of a two stage.Part Ⅱ: The comparativeness of couples property system in China, France, and Germany. This section briefly introduces the matrimonial property regimes, and on this basis compares the marital property systems. This article introduces Chinese legislation general situation from both the legal property system and undertaking property system, and then introduces French and Germany legislation general situation property system from both the legal property system, undertaking property system and some regulations. Followed by the comparativeness with marital property system, legal property system, undertaking property system and individually owned property system, we draw the difference and the same and then the causes in France, Germany and China.Part Ⅲ: The perfection of marital property system. In the second part of our comparison drawn with France, Germany and the differences between property systems, in conjunction with China's specific national conditions, the article put forward some corresponding improvement and refinement of the legislative proposals. The part gives give some improved suggests on marital property system, legal property system, undertaking property system, individually owned property system and special property system. In logic structure of martial property system, we should...