Matrimonial regime

A matrimonial regime, also called a marital property regime, is the system of law that governs how property is owned, managed, divided and inherited between spouses, operating either automatically by default under a country's law or by a prenuptial agreement in jurisdictions that allow couples to choose their own arrangement. Common law countries have traditionally defaulted to separation of property, keeping each spouse's assets legally distinct, though a number of United States states instead use community property systems in which most assets acquired during marriage are jointly owned. Civil law jurisdictions such as France, Germany, Italy and the Canadian province of Quebec typically set a statutory default regime, often some form of community property, which spouses may then modify by contract, and under the Hague Convention a small number of countries, including the Netherlands, let spouses choose a property regime from any country where they hold citizenship, residence or real estate. English common law once imposed coverture, under which a married woman's legal identity and property rights were absorbed into her husband's, a doctrine only dismantled through married women's property acts passed over the course of the nineteenth century; modern hybrid systems such as Germany's participation regime instead keep property separate during the marriage but share any profit made on it once the marriage ends.