Substantive Law and Conflict of Laws Aspects Related to Spouses’ Property in Russian and English Law

The dissertation is devoted to the comparative legal analysis of the regulation of financial consequences of divorce in the Russian Federation and in England. The author highlights the differences in the matrimonial property regimes under English and Russian law, as well as in approaches to the regulation of marital property agreements, gives a general description of marriage contracts in the Russian Federation, defines the conditions for the validity of marital property agreements in accordance with English law, describes the approaches of English courts to assessment of marital property agreements. In addition, the work covers conflict of laws aspects related to spouses’ property in Russian and English law. In conclusion, the author summarizes the comparative analysis that has been carried out and highlights the most significant differences, firstly, in the regulation of relations over property between divorcing spouses in Russia and England and, secondly, in the regulation of marital property agreements in these two countries. At the same time, based on the results of the conducted analysis, it is proposed to make some amendments to the Russian family legislation.