Nuptial Contracts for International Couples
Getting Married Across Borders? What You Don't Know About Matrimonial Regimes Could Cost You.
You’re getting married in France to someone of a different nationality. Or you married abroad and have now moved to France. Or you’ve been married for years, living between two countries, and never thought about which law governs who owns what.
In each of these situations, the question of your matrimonial property regime — the rules that determine how assets are owned, managed, and divided during and after a marriage — may not be governed by the law you think it is. And the default rules in France are very different from what you’d expect if you come from a common-law country.
If you don’t actively choose a regime, one is imposed on you — and it may not be the one you’d have chosen. If you do choose one, it needs to be done correctly and in the right form, or it may not be recognised in one of the countries involved. If you divorce, the question of which country’s rules apply to dividing your assets can produce outcomes that neither party anticipated.
These are not problems that sort themselves out. They require decisions made in advance, with a clear understanding of how the relevant legal systems interact.
Why This Is a Former Notary's Specialist Area
Nuptial contracts — contrats de mariage — are one of the core documents that French notaries draft and authenticate. Julie Gordon’s years in notarial practice mean she has hands-on experience of how matrimonial regimes work in practice, how they are structured, and what happens when they need to be applied or modified.
As a specialist in international law, she now focuses specifically on the situations where couples from different countries, or couples with assets in multiple jurisdictions, need a matrimonial arrangement that works across borders — not just in one country.
Situations We Work With
International couples face a range of situations where their matrimonial regime matters more than they realise. Our clients come to us when they are:
Getting married in France and one or both partners is a foreign national
Considering a prenuptial or postnuptial agreement that needs to be valid in more than one country
Already married and unsure which country’s matrimonial rules apply to them
Moving to France from abroad and discovering their existing arrangements may not be recognised
Going through a separation or divorce and facing questions about which law governs the division of assets
Planning ahead to protect assets, business interests, or family wealth across borders
For many international couples, the marriage contract is as much about inheritance planning as it is about the marriage itself — French forced heirship rules can override your expectations if your matrimonial regime isn’t properly structured. → International Inheritance & Succession
Determining which country’s matrimonial rules apply to your situation is a question of private international law — and the answer isn’t always what you’d expect. → Private International Law
Contact Us
If you are part of an international couple and need to understand your matrimonial situation under French law, contact us for a consultation.