Dansuri (cvasi)matrimoniale şi succesorale în context transfrontalier – crux iuris?
Cross-border interactions between (quasi-)matrimonial property and succession regimes – crux iuris?

Summary/Abstract: Given the increased mobility of couples, who are increasingly placed in a cross border context, the issues currently raised by matrimonial property regimes and their interaction with succession law constitute one of the most important branches of private international law. The interaction between the two legal systems may give rise to complex issues, such as the concurrent application of different laws, particularly where the applicable law is determined based on objective connecting factors, as well as difficulties in legal classification especially in determining whether a right falls under the matrimonial property regime or the law of succession. Another sensitive issue addressed in this study concerns the recognition of the succession rights of the surviving partner and of the same sex surviving spouse in the territory of a State (such as Romania) that does not regulate same sex unions and that also refuses to recognize the legal effects of such unions validly concluded abroad.

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