Abstract

A. INTRODUCTION B. THE NATURE OF THE RELATIONSHIP C. INTERNAL SCOTS LAW (1) Household goods (2) Money and property (3) Financial relief on termination D. SCOTTISH CONFLICT OF LAWS PERSPECTIVE E. JURISDICTION (1) Possible bases of jurisdiction (2) Council Regulation (EC) No 44/2001 (3) Residual Scottish rules of jurisdiction (4) Law Commission proposals for England and Wales (5) Jurisdiction of the English courts in family law (6) The need for new rules of jurisdiction (7) Conflicting jurisdictions F. CHOICE OF LAW (1) The position under the 2006 Act (2) Problems of mutability (3) Formulating a choice of law rule (4) Cohabitation contracts and opt-out agreements G. RECOGNITION OF OVERSEAS DECREES H. EU GREEN PAPER (1) Harmonised rules of jurisdiction (2) Harmonised choice of law rules I. CONCLUSION

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