Three basic property models
Under community of property, what is acquired during the marriage belongs to both and is divided on dissolution. Under a deferred community or accrual system, the estates stay separate and only the growth is equalised. Under separation of property, each keeps what is in their name. Which one applies by default varies between countries — and it is that default, not the spouses' sense of fairness, that governs the division later.
The family home is treated separately almost everywhere
Whatever the regime, most systems protect the home: it cannot be sold or the tenancy ended without the other spouse's agreement, and on separation courts decide occupation on their own criteria, usually following the children. Looking only at whose name is on the title consistently underestimates these rules.
Inheritance: forced heirship or freedom of disposition
This is the second great dividing line. One group of countries protects close relatives through reserved shares that the deceased cannot give away; a will that ignores them will be challenged and reduced. The other grants broad testamentary freedom and corrects only through maintenance claims by dependants. Anyone with assets in more than one country has to keep both systems in view at once.
Unmarried partners do not inherit
That is the rule almost everywhere, regardless of how long the relationship lasted. Without a will, the estate passes to the deceased's children, parents or siblings. For unmarried couples a will is therefore not an optional refinement but the only protection there is — and it should be drafted around any reserved shares so that it survives challenge.
Time limits after a death are short
Reporting the estate, renouncing an insolvent inheritance and filing tax declarations are often measured in weeks or a few months. In several systems, doing nothing makes you an heir by default — debts included. Get a picture of assets and liabilities straight away, before deciding anything else.
Two countries, two laws
A marriage celebrated abroad or with a foreigner, the law that governs the couple's property, children of two nationalities, an estate spread over two countries: the page on international couples gathers the common rules and explains the Hague Conventions.
The law country by country
The legal framework, the procedure, the time limits and the costs differ from one country to another. Each country below has a detailed page: governing texts, key facts, the actual procedure, costs, where to go and the traps to avoid.
Select a country to open its detailed page.