Regimul matrimonial cu implicaţii transfrontaliere – delimitări conceptuale, lex causae
The matrimonial property regime with cross-border implications – conceptual delimitations, lex causae

Summary/Abstract: The matter of the matrimonial regime with an element of foreignness is governed, from the perspective of the Member States, by parallel regulations – Regulation (EU) 2016/1103 and national private international law. An examination of the notion of “matrimonial property regime” reveals notable differences, generated by the autonomous qualification contained in the Regulation and by the functional qualifications, in the law of the European states. An analysis of the lex causae highlights elements of similarity and, at the same time, particularities – In relation to each component of the matrimonial property regime. The example refers to the Romanian private international law, both in terms of the notion of “matrimonial property regime” and in terms of the subjective and objective determination of the law applicable to the regime.

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