Joint, Solidary and Community Obligations: Approaches to Spouses’ Liability for Debts in the European States
Kosice Days of Private Law (Košické dni súkromného práva), 1st edition, Kosice, 2016, pp. 237-256.
22 Pages Posted: 1 May 2016 Last revised: 26 May 2016
Date Written: April 22, 2016
The paper is devoted to theoretical research of the models of spousal liability for debts, which have been developed in Europe. The author first describes present matrimonial property regimes of the European states and then elaborates on existent types of obligations within the framework of marital property relations. Based on the core of spousal obligations and their fulfilling mechanisms the author distinguishes and analyses a number of legislators’ approaches to spousal liability for debts incurred under the certain matrimonial property regime. Finally there are conclusions concerning perspectives of harmonisation activity in the field of spousal liability for debts in the European states.
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