FLiP 33 - Should I Divorce in England or France? Comparing Divorce Laws and Financial Remedies
Description
Divorcing across borders can feel daunting - especially when the choice of country could shape the outcome especically with regards to the financial settlement. In this episode, David Allison and Isabelle Rein-Lescaterreyes compare the approaches in England & Wales and in France, highlighting the key differences couples should be aware of before deciding where to issue divorce proceedings.
Their conversation covers:
- Jurisdiction for divorce in light of the EU system
- Issues with sole domicile and The Hague Convention
- Financial remedy relief in the context of the Matrimonial Property Regime (France)
- Financial remedy relief under the Matrimonial Causes Act 1973 (England)
- Pre-Nuptial Agreements
- Cultural differences in relation to the concept of "needs"
- Maintenance provision
- Costs and privacy
- Jurisdiction races
- Overseas financial relief in light of Part 3 proceedings
About the speakers:
David Allison, Family Solicitor, Family Law in Partnership
David Allison is a director at Family Law in Partnership and a leading family lawyer with particular expertise in international divorce and financial claims. He represents business owners, entrepreneurs, bankers, lawyers, and their partners, often in high-value cases involving complex jurisdictional disputes and overseas assets. David has extensive experience securing recognition and enforcement of foreign judgments and advising clients on financial relief following overseas divorces.
https://www.flip.co.uk/profiles/david-allison/
Isabelle Rein-Lescastereyres, Family Solicitor, BWG
Isabelle is a partner at BWG. She is bilingual and has many years of experience in complex international situations, in particular with neighbouring French-speaking and English-speaking countries. Isabelle favours "a realistic and constructive approach in order to maximise chances for a rapid conflict resolution".
With her HEC (Ecole des Hautes Etudes Commerciales) training, Isabelle advises individuals, families and trusts and represents them in all aspects of divorce and family law, particularly in dealing with complex patrimonial and financial issues.
In particular, she assists French expatriates and foreigners residing in France on family and patrimonial issues relating to their international mobility.
https://bwg.law/en/avocat/isabelle-rein-lescastereyres/
Both Isabelle and David are members of the International Academy of Family Lawyers (IAFL).



