When a couple lives across two countries, or one spouse moves abroad, three questions arise from the outset: which court to apply to, which law applies, and whether the decision will be recognized in the other country. The answers depend on the country involved.
For twelve countries where many French or mixed-nationality families live, these pages present local law and its connections with French law.
Each page follows the same route: your situation, competent courts, applicable law, recognition of the decision or agreement, then local rules for your relationship, children and assets, and my support. It also identifies country-specific points to watch and links to official texts.
Within the European Union
Belgium · Germany · Spain · Italy · Portugal
European regulations identify the competent court and applicable law and provide recognition of decisions, including divorce by mutual consent signed by lawyers. Differences concern each country’s procedure, maintenance, matrimonial property and civil status. If two proceedings begin, the first court seised takes priority: the date matters.
Outside the European Union
United Kingdom · United States · Switzerland · Canada · United Arab Emirates · Singapore · Hong Kong
No common rule identifies the court or organizes recognition: each country applies its own rules, and results, particularly financial results, can differ substantially depending on the court chosen. Only certain international conventions on children or maintenance provide a shared framework.
An initial overview, not a legal consultation
These pages provide an overview at their publication date. They do not replace a consultation: every case depends on specific facts and local law changes. For each case, I work with a colleague in the country concerned, who confirms the local-law analysis for your circumstances and acts before local courts when necessary.
Act early, negotiate first
In an international separation, the first weeks are often decisive: choice of court, form of divorce and protection of children need preparation before taking steps. An international consultation compares your options in both countries. Wherever possible, I then favor negotiation or international family mediation, designed from the start for recognition in both countries.