International family law map
Which court?Which law?
As soon as a family has a link with another country, two questions come before all others: which court to turn to, and which law it will apply. This map answers them for couples, children and property, from the simplest to the most technical level.
- Member of the Paris Bar
- Doctor of Law
- CNMA-listed mediator
- FR / EN
The map
Unfold the branches, from court to law
Click a question: its branch unfolds down to the rules. Drag to move around; zoom with the buttons, by pinching the screen or with Ctrl + scroll wheel.
Tip: each question also leads to its full sheet, further down.
Before reading the map
Three first steps
The same family may fall under several courts and several laws at once. Taking these three steps, in this order, avoids most mistakes.
- 1
Spot the foreign links
Each person’s nationalities, countries of habitual residence (today and after the marriage), location of assets.
- 2
Take each question separately
Divorce, children, support, assets: each question has its own court and its own law. The divorce court does not necessarily decide everything.
- 3
Check the dates
Date the court is seized, date of the marriage, date of death: depending on the date, a different text applies.
Key
- Any of theseSeveral possible answers, in no particular order. Between courts, the first one seized prevails.
- In orderMove to the next step only if the previous one does not apply.
- Parties' choiceThe spouses, the parents or the deceased may choose, in writing.
- Rule and exceptionsA basic rule, then the cases where it gives way.
Browse
The PDF guide
The map, to take with you
The whole map in a 13-page guide, the first of the four “Toolkit Guides”: one page per question, the court on the left, the law on the right.
- Browse it freely online.
- Receive it free of charge by email, as a personal copy in your name.
- Updated .
Protected document, for strictly personal use: no reproduction or distribution without permission.
What next?
Knowing the court and the law means knowing what to negotiate
Knowing which court can hear the case and which law it will apply means measuring what each side would gain or lose in court. I use this analysis to build a solid agreement, and I bring the case before the best-placed court if negotiation fails.
Official texts
Disclaimer
This map sets out general rules, updated . It deliberately simplifies complex texts, which contain conditions, exceptions and dates of application. It is not a substitute for legal advice: every international family situation must be analyzed in light of its facts, the nationalities and residences involved and, where relevant, foreign law.