涉外夫妻财产关系法律适用之探讨

The Application of Law of the Foreign-related Spouse Property Relationship

涉外婚姻法律适用问题历来为各国所重视,对涉外夫妻财产关系的法律适用,主要有意思自治原则、夫妻属人法、最密切联系原则等。我国立法对涉外夫妻财产关系适用的法律未作规定,不能适应涉外婚姻的现实需要,应该依据我国国情,参照国外的先进做法,完善涉外夫妻财产关系立法。

The problems concerning law application of foreign-related marriage has always attached great importance for states,the main principle of which including: the principle of autonomy,common law principles of husband and wife,and the most close-link principle,etc.China has not been provided for legislation on foreign relations applicable to matrimonial property,consequently can not meet the practical needs of foreign marriage.We should base on the condition of our country,in the light of advanced practices,imp...