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Find out more about some of the international jurisdictions we have experienced with our clients.
Click on the darker areas of the map to find out more about divorce and family law in those locations.
In Algeria the Family Code regulates issues that arise during divorce. The country is a predominantly Muslim one and the UN has indicated that the Code is directly influenced by Islamic law. Women have fewer opportunities to divorce in Algeria and they have fewer property rights.
Angola is a former Portuguese colony. Following independence in 1975 it inherited elements of Portugal’s civil law system, and there is a comprehensive Family Code that sets out the rules on divorce. Although some minority groups in certain regions of the country don’t recognise the concept of divorce, Article 78 of the Family Code allows either spouse to issue a petition for divorce...
Argentinian family and divorce law is governed by the Civil Code. But there is a degree of flexibility available to family judges that’s not always present in countries where the law is codified. Argentinian courts rely heavily on previously decided cases in the way English judges do, helping to ensure that divorce settlements are appropriate in each individual case.
Brookman Solicitors have a long standing relationship with Australia and New Zealand. Henry Brookman, an Australian himself, has worked for many years in both the Australian and English legal systems and is uniquely positioned to help clients from this part of the world.
Austria’s divorce law and its matrimonial property regime is enshrined in the Austrian civil code. For example, the principle of the separation of property applies throughout the period of marriage.
Bangladesh is a country which operates its family law on the basis of Sharia (Islamic) law. We regularly deal with cases involving Bangladeshi nationals, or those who married them.
With its colonial past and membership of the Commonwealth, Barbados and the courts there are still influenced to a degree by English law and custom.
Belgium is at the heart of the EU and accordingly is party to all the relevant European regulations. It is also signatory to the Hague Convention on the International Aspects of Child Abduction. The divorce procedure involves a compulsory preliminary reconciliation stage which can delay matters.
Under Article 207 of the Bolivian Family Code, men and women have equal rights to start divorce procedures, and there are three methods of divorce...
We were recently successful in winning a jurisdiction battle which enabled the proceedings to continue in Brazil rather than in England.
The Burkinabe legal system is based on the French civil law system. However custom and traditional marriages – outside the scope of the civil law regulations – account for a large percentage of marriages in the country.
There are significant differences in the way the courts in Bulgaria and those in England decide family law issues. So it’s essential to get specialist family law advice if your case includes an element of Bulgarian law or either spouse is Bulgarian.
The Cambodian family law system is influenced by the French civil system and by customary law. It also contains elements of common law (originating from Britain) and of Vietnamese law. There is a Civil Code (2007) and a Constitution that represents the supreme law of the country.
The laws relating to divorce are set out in the Civil Code, but Cameroon is almost unique in recognising customs of the country – legal cases in many areas may be decided using local custom handed down through the generations. In practice therefore there is a ‘dual’ legal system: Divorce and other family law disputes may often be decided using ‘native law’ in conjunction with the Civil Code...
There is a uniform divorce law enacted by the central government but administered by the provincial courts. Therefore the lawyers concerned should be practising within that province. Brookman has dealt with numerous cases relating to Canada.
Chad still uses the French Civil Code of 1958. Reform is underway but discussions on a new Code of Persons and Family for Chad has been under discussion for at least two decades. Under the French law, marriage is based on consent and women are afforded the same rights to marry as men.
Where one or both divorcing spouses have a legal or other kind of connection to Chile the process can become complicated. Both the laws of Chile and those of England can potentially dictate the financial settlement and arrangements for children.
If you are an expatriate living in China then you may find that you fall into a legal vacuum. China may refuse to deal with your matter so we would strongly recommend you discuss your issue with Brookman who have dealt with Chinese cases previously.
For international couples the Colombian courts have wide powers to take on responsibility for dealing with a divorce, including the financial aspects of separation. Not only British couples living in Colombia can get divorced there – so too can British couples who have left the country but still have a right to reside there. This has consequences for individuals who may wish to divorce in England and Wales.
Divorce in Croatia is regulated by the Family Proceedings Act, 2015 (‘the Act’). The legislation represents a major overhaul of the law on divorce, notably in relation to arrangements for children. Under Article 51 of the Act there are three ways to divorce...
The Czech Republic law on divorce is very consistent with other continental European countries. There is a civil code which sets out the rules for divorce, financial arrangements and decisions on children matters.
Denmark is not a signatory to the Brussels II (bis) which makes it an anomaly within Europe if there is any argument as to jurisdiction. We have experience dealing with Debmark so can advise clients how they may best proceed.
Historically Egyptian family law and divorce has tended to favour and protect the economic and social status of husbands at the expense of wives. To a degree this is still the case but the system is changing and widespread reform of the law has been proposed.
Ecuador’s legal system for example is a civil system, based on binding laws collected in the Civil Code (the Code). The country also has a constitution. The Code gives men and women equal rights to issue divorce petitions on the basis of mutual consent or for cause.
Family law in Estonia underwent a major shift with the 2010 Family Law Act (the FLA). The legislation promoted the idea that husbands and wives should take responsibility for the way they held property together. When a couple applies for a marriage licence in Estonia they also have the opportunity to choose the marital property regime they want, choosing between...
The choice of jurisdiction can make a big difference to any divorce outcome. Spousal maintenance for example, is restricted in Ethiopia. We advise clients in circumstances where they may have the choice to divorce in either Ethiopia or through the courts of England and Wales.
Finland is a member state of the European Union and as such is party to the cross border regulations dealing with divorce. No grounds are required for a divorce in Finland.
Brookman was recently successful in defeating an application under the Hague Convention made by a French National.
There’s no need to involve the courts if both spouses agree to the divorce, there are no children and there is no dispute over property. This kind of divorce by mutual consent is simply registered at the local Register of Civil Status. One spouse can also apply for divorce if the other spouse...
English and German expats can potentially obtain a divorce in either England or Germany. And the precise nature of the final settlement is often shaped by the approach of the judges in the country that hears the divorce. Prenups for example are sometimes easier to enforce in Germany than in England and Wales...
The state of Ghana recognises three types of marriages – ordinance, customary and Islamic. Customary marriages and breakdown are generally governed by the customs relevant to a particular region. Other marriages are regulated by The Matrimonial Causes Act, 1971 (the MCA) and the Marriage of Mohammedans Ordinance 1907...
Gibraltar’s family law closely matches that of England. Furthermore, the grounds of jurisdiction are very similar, and although Gibraltar is not an EU country, nevertheless it adopts certain EU Regulations to achieve consistency in the exercise of jurisdiction.
There are two procedures for obtaining a divorce in Greece. We are experienced in handling divorce and family cases relating to Greece and the EU countries.
Guinea is predominantly a Muslim country. It’s estimated that 85% of the population adheres to the Islamic faith. Religious and customary practices influence marriage and divorce law despite the existence of a Civil Code. Differences between the divorce procedures in Guinea and the UK vary widely...
In order to start divorce proceedings in Hong Kong the parties must have a substantial connection with the jurisdiction. We have experience dealing with Hong Kong so can advise clients how they may best proceed.
Like most Latin American countries, Honduras has a civil law system. Unlike the common law system of law in the UK (where the law is developed largely through reliance on previous court decisions), the general law in Honduras is set out in the Civil Code, and the regulations on divorce are contained in the Family Code.
We are regularly involved in cases with an international dimension. This includes divorce of Hungarian nationals or divorce of individuals with a connection to Hungary. Our clients may be seeking a divorce, or have issues relating to their family finances or are wishing to resolve a dispute regarding children.
Indian statute applies different rules to marriage and divorce, depending on the parties’ personal circumstances. We have particular expertise in dealing with such issues concerning parties who have connections to England and Wales.
Family law and divorce regulations in Indonesia are strongly influenced by cultural and religious factors. We represent UK clients living there as well as Indonesians resident in the UK who need to navigate the divorce laws of both countries to secure a settlement.
It is well known that Iran adheres to its school of Sharia law. This overlays a civil system that records family status. Hence there is a register that records whether someone is single, married or divorced, and although the divorce has to be religious, the fact of it is noted on the register.
Ireland is a later comer to divorce law, but we are nonetheless experienced in matters relating to Ireland. The courts and procedure are based on the common law model, and the Irish and English common law jurisdictions have historically contributed greatly to each other.
Divorce under Italian law can be complex – we have a great deal of experience in advising Italian clients on the best route to take.
Recognition of Japanese divorces can be problematic, in particular as to Kyogi Rikon divorces. We have extensive experience of these.
Kenya is a diverse and multi-ethnic country. The Marriage Act, 2014 recognises civil marriages as well as those performed under customary law and under the Christian, Hindu and Islamic traditions. All marriages must be registered and, while Islamic marriages and their dissolution are governed by religious courts, they are still subject to the overarching equality provisions of the Kenyan constitution...
Lithuania has one of the highest divorce rates in the EU. Divorce here can be by mutual consent, provided a year has passed since getting married and there is a comprehensive settlement agreement in place that deals with children and finances...
As international family lawyers we represent clients from Luxembourg living in the UK who are going through divorce. We also act for people who may have got married in Luxembourg, whose spouse is from the country or who have some other link to the country.
British colonial influence in countries like Malaysia is illustrated by the impact English law still has on the territory. 1956 legislation enables Malaysian judges to apply English common law in family matters where no equivalent Malaysian law has been introduced.
We are specialist international divorce and family lawyers. We advise clients who are either UK-based but originate from the Maldives or who were married in the Maldives. We also act for people who need family law advice and who have some other link to the country.
As international family lawyers we sometimes act for clients who are getting divorced and who have some legal connection to Malta. One spouse may be from Malta for example or the marriage may have been celebrated there. Alternatively the couple may have resided in Malta during the marriage.
Under the Malian Family Code, 2011 women have the same rights as men to enter marriage. Since the adoption of the Code religious marriages are subject to the same formalities when it comes to registration and dissolution as civil unions...
Mauritian family law is heavily influenced by the island’s French and British colonial past. Since independence the family and divorce laws have been amended several times in an effort to redress some of the inequality that previously existed in relation to property rights.
Mexico deals with divorce matters for its own residents. Usually, to initiate a divorce, you must be a legal resident in Mexico. Because Mexico operates a federal system, there can be a great discrepancy between different states and how they operate.
As is well known, Monaco is a self-governing principality. Whilst its foreign affairs are subject to France, it is not a member of the EU and accordingly does not come within the network of regulations.
Morocco operates a personal status law known as the “Mudawna”. This is essentially the family code of Morocco and is based on Sharia jurisprudence.
Divorce is regulated in Chapter Three of the Nepalese National Civil Code. Couples can seek a divorce by mutual consent or, in the absence of agreement one party can petition the court for divorce.
The Netherlands law in relation to the breakdown of marriage and welfare of children principally relies on the Dutch Civil Code, and its particular chapters relating to family law, separation and dissolution of marriage.
New Zealand grants divorces on the basis of separation. New Zealand legislation sets quite strict guidelines as to how financial outcomes are to be decided.
Nigeria has a Matrimonial Causes Act to regulate divorce. However there are several marriage systems in Nigeria and each frequently take charge of their own procedures. In principle, divorce is on a ‘no fault’ basis although fault frequently appears to be used in argument.
Norway is not a member state of the EU and accordingly the EU regulations do not apply. There is divorce as of right if the parties have been separated for a year.
The Philippines is the only UN member country, apart from Vatican City, that does not currently permit divorce. The Family Code does include provisions for alternatives to divorce, including annulment. We act for Filipino citizens and those with a connection to the country who may be impacted by Filipino family law when they want to divorce.
A great deal of care is required in respect of recognition of divorces from Pakistan. Professional legal advice is strongly advised.
Recent legislation in Papua New Guinea has gone some way towards balancing the rights of spouses on divorce. There are however significant differences in approach of the courts there and the courts in England and Wales when it comes to deciding issues around divorce.
Paraguay has one of the lowest divorce rates in Latin America. With a large Catholic population, legalisation of divorce occurred only in 1992. There are profound differences in the approach to divorce and family law taken by the Paraguayan courts and the courts in England and Wales.
It’s a common misconception that if you live in Peru you must get divorced there. Conversely some people incorrectly assume that if they have been married abroad they aren’t subject to Peruvian divorce law.
It is not uncommon for individuals who have a connection with Poland to be able to divorce in England. It is certainly worth seeking early advice from a lawyer as the choice of country in which proceedings take place may well be important, particularly in terms of the financial outcomes.
The divorce rate in Portugal is around 70%. Even though the rate is high it has actually decreased in recent years. We advise clients with a connection to Portugal on a wide range of family law matters, including divorce and child arrangements following separation or divorce.
When divorce is overseen properly, Russia is known as having one of the world’s most lenient procedures, and couples are sometimes able to end their marriages in a single court procedure. However we would recommend you discuss your issue with Brookman who have dealt with Russian cases previously.
Saudi Arabian family law is dealt with by Sharia law. Any proceedings in that country must strictly adhere to Islamic law. Therefore parties with a connection to England should check the position of any Saudi ruling carefully.
Some of the grounds for divorce in Scotland differ from those in England. In Scotland, the grounds for divorce are: Behaviour, Adultery, One year's separation with consent, Two years' separation without the requirement of the other party's consent.
Many British nationals marry at popular holiday destinations such as the Seychelles for example. Can such a marriage be dissolved in the UK? The short answer is yes – provided the usual rules on UK residence and domicile are met.
We regularly deal with South and East Africa. In recent years we successfully concluded a ground breaking Child Support case relating to South Africa.
Singapore derives its legal system and procedures primarily from the common law (British) tradition. Its Courts have increasingly been asked to intervene in international matrimonial disputes.
The Catholic Church retains a significant degree of influence in Slovakia. Religious opposition to divorce in part explains the continued conservative approach to the law in this area. Couples who wish to divorce must prove to a judge that the marriage is dysfunctional, even if both parties agree to a divorce...
Most divorces in Slovenia are by agreement between the spouses. There is no equivalent of the requirement in England and Wales to prove fault. If there are children, parents must agree a parenting plan before a divorce is granted. Courts will then look at the agreement and decide whether or not it is in the interests of the children...
The legal systems in the UK and South Korea are very different. We provide the specialist legal advice that’s needed when UK citizens based in South Korea and Korean people living in the UK are getting divorced.
If an English couple have been living in Spain for a number of years they can apply for a divorce in their local Spanish Court. However, they would need to establish grounds for divorce under the laws of England.
In Sudan, the right to divorce will vary according to the religion of the spouses. Under the Muslim Personal Law a husband can initiate and finalise divorce himself (talaq) whereas a woman must initiate court proceedings to obtain a divorce. And then only in limited circumstances, including...
Divorce in Sweden is governed by the marriage code. Throughout the marriage each spouse individually continues to own all of his or her property. There is no liability for the other’s debts. However a divorce triggers a potential claim to have the assets treated as ‘community property’, in principle to be divided equally.
Switzerland is a confederation of 26 cantons, with legislative competence divided between the confederation and the cantons. Federal law governs family and divorce matters. However such matters are dealt with in the Courts of the individual cantons, so the procedural law may vary considerably.
The Law of Marriage Act, (LMA), updated in 2019, is the main legislation governing marriage and divorce. Those domiciled in Tanzania and those resident in the country for at least a year can petition the court for divorce. In essence the courts will only grant a divorce if it is satisfied that the marriage has irretrievably broken down...
We act regularly for UK clients living in Thailand as well as Thai citizens in the UK and others with a connection to Thailand who wish to divorce. Culturally the legal system in Thailand is markedly different from the legal system in England and Wales.
Where there is the possibility that your divorce could be finalised in either Tunisia or the UK we can provide up to date advice and clarity as to where you might obtain a more satisfactory settlement.
Turkey is a country which operates a civil code, notwithstanding many of its citizens being conservative Muslims.
We act for many clients within this jurisdiction, be they UAE Nationals living in England or Wales, or British expatriates residing there.
Ukraine is a civil law jurisdiction. The Family Code determines the principles of marriage, financial arrangements within marriage and upon divorce, and obligations in relation to children.
Brookman often deals with cases linked to the USA. There is no uniform “US divorce law” - the States broadly divide into those where the law derives from English common law concepts and those which adopt a more Hispanic formula-based approach.
Divorce came relatively early to Uruguay compared to other countries in Latin America. Divorce on the grounds of a husband’s cruelty was possible in 1907 and by 1912 women could petition for divorce without a stated cause. More recently same-sex marriage was legalised in the 2013 Law on Equality in Marriage. The same legislation also redefined the rules relating to payment of alimony, separation and divorce.
Uganda’s family law system has been influenced to a degree by the nation’s British colonial past. But more significantly the rules have been developed in line with local custom. Here we look at the divorce process in Uganda and touch on the key issues you may wish to consider.
The Family Code formally gives men and women an equal right to start divorce proceedings. Article 39 of the Code contains a specific provision preventing a husband from filing for divorce while his wife is pregnant. There is also a requirement that women have a right to seek an equal share of joint property that has been acquired during the marriage.
Vietnam’s Law on Marriage and Family, 2016, provides for divorce by mutual consent and divorce on the request of one party (unilateral divorce)...
Once rare in mainly Catholic Venezuela, divorce has risen markedly in recent decades. There is no longer the social stigma associated with divorce that existed in the past. The Venezuelan Civil Code (Article 185) provides both spouses with the right to petition for divorce.
Here we highlight some aspects of Yemeni divorce practice that may be relevant to your situation should you or your spouse have some legal connection to the Yemeni Republic.
Section 8 of the Zambian Matrimonial Causes Act gives men and women equal rights to petition the High Court of Zambia for divorce. The sole ground for divorce is that the marriage has broken down irretrievably.
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