Who Owns What in a Marriage?
If you marry a foreigner, or marry abroad, what do you and your spouse own by default? Does a salary become joint property? What happens to a house bought before the wedding? This guide explains, country by country, what applies when a couple sign nothing, how property is divided when the marriage ends, and whether a marriage contract can change the rules.
Part of the comparative law toolkit. Each country page links to an official source.
Property acquired during the marriage is joint by defaultSeparate ownership during the marriage, with the gains shared at the endEach spouse keeps their own property; a court may divide it on divorceDepends on the spouses' religion or personal lawDepends on the kind of marriage or on the regime the spouses chooseDiffers by state, region or provinceLighter shade: a general outline for the country's legal tradition, not yet checked country by countryNot yet covered
Read this first
This guide describes the default rules, meaning what applies when the spouses sign no contract. It does not predict what a court would decide in a particular case, and it gives no amounts. Family law changes, and which country’s law applies to a couple with a foreign spouse can be a hard question of its own. If you are marrying across borders, take advice in each country involved before you marry or buy property. This is general information, not legal advice.
Every country covered
The short answer first. Open a country for what is shared, how it is divided, and the marriage contract.
| Country | Default regime | In short |
|---|---|---|
| Albania | Joint (community) | Albania's default is a joint property of the spouses acquired during the marriage. |
| Algeria | Personal law | In Algeria each spouse owns their own property by default, and the family code lets the spouses agree on how to manage property acquired during the marriage. |
| Argentina | Joint (community) | In Argentina the default is a community of acquisitions, but couples can choose separation of property by a marriage agreement, which they can change later. |
| Armenia | Joint (community) | Armenia's default is a joint property of the spouses acquired during the marriage. |
| Australia | Separate property | In Australia spouses own their own property during the marriage, and on separation a court can adjust the division in a way that is just and equitable. Binding financial agreements are allowed. |
| Austria | Separate property | In Austria each spouse owns their own property during the marriage, and on divorce a court divides the assets acquired and the savings made during the marriage fairly. |
| Azerbaijan | Joint (community) | Azerbaijan's default is a joint property of the spouses acquired during the marriage. |
| Belarus | Joint (community) | Belarus's default is a joint property of the spouses acquired during the marriage. |
| Belgium | Joint (community) | Belgium's default is a community of acquisitions: spouses keep their own property and share what they acquire together during the marriage. |
| Bolivia | Joint (community) | Bolivia's default is a community of gains: what the spouses acquire together during the marriage is shared. |
| Bosnia and Herzegovina | Joint (community) | In Bosnia and Herzegovina the family laws of the entities make property acquired by work during the marriage joint, but each entity has its own law. |
| Brazil | Joint (community) | Brazil's default is a partial community of property: what is acquired during the marriage is shared, and what each brought or inherited stays personal. |
| Bulgaria | Joint (community) | Bulgaria's default is a community of acquisitions: what spouses acquire during the marriage through joint effort is jointly owned, and what each brought or inherited stays their own. |
| Canada | Varies by region | In Canada, marital property law is made by each province. In most provinces spouses keep their own property but share its growth on breakdown, and Quebec has a partnership of acquests. |
| Chile | Joint (community) | Chile's default is a conjugal partnership, with options to choose separation of property or participation in gains by agreement. |
| China | Joint (community) | China's default is that most property acquired by either spouse during the marriage, such as wages and business income, is jointly owned. |
| Colombia | Joint (community) | Colombia's default is a conjugal partnership of the property acquired during the marriage, which can be set aside by a marriage agreement. |
| Costa Rica | Gains shared at the end | In Costa Rica each spouse owns their own property, and when the marriage ends the net gains made during it are shared. |
| Croatia | Joint (community) | Croatia's default is a community of acquisitions: what the spouses earn and acquire during the marriage is joint. |
| Cyprus | Gains shared at the end | In Cyprus the spouses keep their own property, and on divorce one can claim a share based on their contribution to the other's property. |
| Czechia | Joint (community) | Czechia's default is a community of the spouses' property: what they acquire during the marriage is joint. |
| Denmark | Gains shared at the end | Denmark's default is a deferred community: each spouse owns their own assets, and on divorce the assets of both are generally shared equally. |
| Dominican Republic | Joint (community) | The Dominican Republic's default is a legal community of the property acquired during the marriage, in the French tradition. |
| Ecuador | Joint (community) | Ecuador's default is a conjugal partnership of the property acquired during the marriage, and spouses can choose separation of property. |
| Egypt | Personal law | In Egypt the personal-status rules apply, each spouse generally owns their own property, and the marriage contract can include agreed conditions. |
| Estonia | Joint (community) | Estonia's default is a community of the property acquired during the marriage. |
| Ethiopia | Joint (community) | Ethiopia's Family Code makes property acquired during the marriage common property, while each spouse keeps their personal property. |
| Finland | Gains shared at the end | Finland's default is that each spouse owns their own property during the marriage, and on divorce the property of both is divided equally. |
| France | Joint (community) | France's default regime is a community of acquisitions: what each spouse earns and buys during the marriage is joint, while what they owned before and what they inherit or are given stays their own. |
| Georgia | Joint (community) | Georgia's default is a joint property of the spouses acquired during the marriage. |
| Germany | Gains shared at the end | Germany's default regime keeps each spouse's property separate during the marriage but equalises the gains made during it when the marriage ends. |
| Ghana | Separate property | In Ghana a spouse's property is their own, and on divorce courts divide property acquired jointly, with equal sharing as the usual starting point for what the couple built together. |
| Greece | Gains shared at the end | In Greece each spouse owns their own property, and on divorce the spouse who contributed to the other's increase in wealth can claim a share of it. |
| Hong Kong | Separate property | In Hong Kong each spouse owns their own property, and on divorce a court divides the assets, using equal sharing as a yardstick that it can depart from where fairness requires. |
| Hungary | Joint (community) | Hungary's default is a community of acquisitions: spouses own what they brought and inherited separately, and share what they acquire during the marriage. |
| Iceland | Gains shared at the end | In Iceland each spouse owns their own property, and on divorce the marital property of both is generally divided equally. |
| India | Personal law | India has no single default regime for marital property. Each spouse owns their own property, personal laws apply, and a court decides on division case by case, except in Goa, which has a community of property. |
| Indonesia | Joint (community) | In Indonesia property acquired during the marriage is joint by default, and a prenuptial agreement, which can now also be made during the marriage, can change that. |
| Ireland | Separate property | In Ireland each spouse owns their own property, and on divorce a court has wide discretion to decide what each should receive. Pre-nuptial agreements are not automatically binding. |
| Israel | Gains shared at the end | In Israel spouses own their own property during the marriage, and at divorce or death the property acquired during the marriage is balanced between them, generally in equal shares. |
| Italy | Joint (community) | Italy's default regime is a legal community: property acquired by either spouse during the marriage belongs to both, while personal property stays separate. |
| Japan | Separate property | In Japan each spouse owns what is in their name, and on divorce one can ask for a division of the property acquired during the marriage, generally in equal shares. |
| Jordan | Personal law | In Jordan each spouse owns their own property, and the personal-status law sets the duties of support between them. |
| Kazakhstan | Joint (community) | Kazakhstan's default is a joint property of the spouses acquired during the marriage. |
| Kenya | Separate property | Kenya's law treats the matrimonial home and household goods, and property acquired during the marriage, as matrimonial property, and divides it according to each spouse's contribution. |
| Kuwait | Personal law | In Kuwait each spouse owns their own property, and the personal-status law sets the duties of support between them. |
| Latvia | Joint (community) | Latvia's default is a community of the property acquired during the marriage. |
| Lebanon | Personal law | In Lebanon marriage and property between spouses are governed by the personal-status law of each religious community, so the rules differ by community. Each spouse generally owns their own property. |
| Lithuania | Joint (community) | Lithuania's default is a community of the property acquired jointly during the marriage. |
| Luxembourg | Joint (community) | Luxembourg's default is a community of acquisitions, in the French tradition. |
| Malaysia | Personal law | In Malaysia Muslims follow Islamic family law and others follow civil law. There is no single default regime, and a court divides property acquired jointly on divorce. |
| Malta | Joint (community) | Malta's default is a community of acquests: what the spouses acquire during the marriage is shared, and each keeps their own earlier property. |
| Mexico | Varies by region | In Mexico spouses choose between a conjugal partnership and separation of property when they marry, and the rules are set by each state. |
| Moldova | Joint (community) | Moldova's default is a joint property of the spouses acquired during the marriage. |
| Montenegro | Joint (community) | Montenegro's default is a joint property of the spouses acquired by work during the marriage. |
| Morocco | Personal law | In Morocco each spouse keeps their own property by default, but the Family Code lets spouses sign a separate document on how to manage the property they acquire during the marriage. |
| Netherlands | Joint (community) | In the Netherlands the default is a limited community: what is acquired during the marriage is joint, as are the debts, while property from before and gifts and inheritances stay personal. |
| New Zealand | Joint (community) | New Zealand presumes an equal share of the relationship property after a relationship of three years or more, and the spouses can contract out of this by agreement. |
| Nigeria | Separate property | In Nigeria spouses in a statutory marriage keep their own property, and a court has discretion on property settlements at divorce. Customary and religious marriages follow their own rules. |
| North Macedonia | Joint (community) | North Macedonia's default is a common marital property: what is acquired by work during the marriage is joint. |
| Norway | Gains shared at the end | Norway's default is a deferred community: each spouse keeps their own property, and on divorce what both own is shared equally, with some exceptions. |
| Pakistan | Personal law | In Pakistan each spouse owns their own property, and the family law of the spouses' religion governs their rights, including the dower for a wife. |
| Paraguay | Joint (community) | Paraguay's default is a community of gains, and spouses can choose separation of property by agreement. |
| Peru | Joint (community) | Peru's default is a community of acquisitions, and spouses can choose separation of property by public deed. |
| Philippines | Joint (community) | In the Philippines the default for most marriages is an absolute community of property: almost everything either spouse owns becomes joint. |
| Poland | Joint (community) | Poland's default is a statutory community of property: everything the spouses acquire during the marriage is joint. |
| Portugal | Joint (community) | Portugal's default is a community of acquisitions, but the law requires separation of property when a spouse is aged 60 or over at the wedding. |
| Qatar | Personal law | In Qatar each spouse owns their own property, and the family law, based on Islamic law, sets the duties of support between them. |
| Romania | Joint (community) | Romania's default is a community of acquisitions: what the spouses acquire during the marriage is joint, apart from personal property. |
| Russia | Joint (community) | Russia's default is a joint property of the spouses: what they acquire during the marriage is jointly owned, whoever's name it is in. |
| Saudi Arabia | Personal law | In Saudi Arabia personal-status rules based on Islamic law apply, and each spouse generally owns their own property, with a duty of support between them. |
| Serbia | Joint (community) | Serbia's default is a joint property of the spouses acquired through work during the marriage. |
| Singapore | Separate property | Singapore has no default marital property regime. Spouses keep their own property during the marriage, and on divorce a court divides the matrimonial assets in a just and equitable way. |
| Slovakia | Joint (community) | Slovakia's default is a joint ownership of the spouses' property acquired during the marriage. |
| Slovenia | Joint (community) | Slovenia's default is a joint property of the spouses acquired through work during the marriage. |
| South Africa | Joint (community) | In South Africa a civil marriage is in community of property by default, unless the spouses sign an antenuptial contract before the wedding. |
| South Korea | Separate property | In South Korea each spouse owns their own property, and on divorce the court divides the property acquired during the marriage according to each spouse's contribution. |
| Spain | Varies by region | In most of Spain the default is a community of gains, but several regions have their own default, such as separation of property in Catalonia and the Balearic Islands. The regime depends on the spouses' civil status as set by region. |
| Sri Lanka | Joint (community) | In Sri Lanka a marriage under the general law is in community of property unless the spouses sign an antenuptial contract, while Kandyan and Muslim law have their own rules. |
| Sweden | Gains shared at the end | In Sweden each spouse owns their own property during the marriage, but on divorce the marital property of both is generally divided equally. |
| Switzerland | Gains shared at the end | Switzerland's default is a participation in acquisitions: each spouse owns their own property, and on divorce the gains made during the marriage are shared equally. |
| Taiwan | Gains shared at the end | Taiwan's default is that spouses keep their own property, and when the marriage ends the surplus each spouse built up is equalised. |
| Tanzania | Separate property | In Tanzania each spouse owns their own property, and on divorce the court divides the assets the couple acquired by their joint efforts during the marriage. |
| Thailand | Joint (community) | Thailand separates each spouse's personal property from the marital property, which is shared, and the spouses can sign a prenuptial agreement when they register the marriage. |
| Tunisia | Separate property | In Tunisia the default is separate property, and spouses may choose an optional community regime by a marriage contract. |
| Turkey | Gains shared at the end | Turkey's default regime is participation in acquired property: each spouse owns their own assets, and the property acquired during the marriage is shared when it ends. |
| Ukraine | Joint (community) | Ukraine's default is a joint property of the spouses: what they acquire during the marriage belongs to both, and they can agree otherwise in a marriage contract. |
| United Arab Emirates | Personal law | In the United Arab Emirates the rules depend on the spouses' religion and personal law. For Muslim spouses each spouse generally owns their own property, and non-Muslims may have civil rules in some emirates. |
| United Kingdom | Varies by region | In England and Wales spouses keep their own property during the marriage, and on divorce a court has wide discretion to divide it fairly. Scotland has its own rules, which share the property acquired during the marriage. |
| United States | Varies by region | In most US states spouses own what is in their name and a court divides marital property fairly on divorce. Nine states have a community property system, where property acquired during the marriage is joint. |
| Uruguay | Joint (community) | Uruguay's default is a conjugal partnership of the gains acquired during the marriage, and spouses can choose another regime by agreement. |
| Uzbekistan | Joint (community) | Uzbekistan's default is a joint property of the spouses acquired during the marriage. |
| Venezuela | Joint (community) | Venezuela's default is a community of the gains acquired during the marriage. |
| Vietnam | Joint (community) | In Vietnam the default is common property of the spouses, which covers what they earn and acquire during the marriage, and they can agree on another arrangement before the wedding. |
General outlines
These countries have not yet been researched line by line. Each page is a general outline built from the country's legal tradition, with a plain note on why information is hard to find. If you know the law in one of them, please email us what it says and where it is written.
| Country | Default regime | In short |
|---|---|---|
| Afghanistan | Personal law | In Afghanistan family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Andorra | Depends on the marriage or the choice | Andorra has a civil-code system of its own, in which the spouses have a legal regime unless they choose another by contract. |
| Angola | Joint (community) | Angola's Family Code makes a community of acquests the default: what the spouses acquire during the marriage is shared. |
| Antigua and Barbuda | Separate property | Antigua and Barbuda follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Bahamas | Separate property | Bahamas follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Bahrain | Personal law | In Bahrain family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Bangladesh | Depends on the marriage or the choice | Bangladesh has its own family code, and religious or customary rules also apply to many marriages. |
| Barbados | Separate property | Barbados follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Belize | Separate property | Belize follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Benin | Depends on the marriage or the choice | Benin follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Bhutan | Depends on the marriage or the choice | Bhutan has its own family code, and religious or customary rules also apply to many marriages. |
| Botswana | Depends on the marriage or the choice | Botswana follows the Roman-Dutch tradition for civil marriages, and customary marriages follow customary rules. |
| Brunei | Personal law | In Brunei family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Burkina Faso | Depends on the marriage or the choice | Burkina Faso follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Burundi | Depends on the marriage or the choice | Burundi follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Cabo Verde | Joint (community) | Cabo Verde's Family Code makes a community of acquests the default: what the spouses acquire during the marriage is shared. |
| Cambodia | Depends on the marriage or the choice | Cambodia has its own family code, and religious or customary rules also apply to many marriages. |
| Cameroon | Depends on the marriage or the choice | Cameroon follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Central African Republic | Depends on the marriage or the choice | Central African Republic follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Chad | Depends on the marriage or the choice | Chad follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Comoros | Depends on the marriage or the choice | Comoros follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Côte d'Ivoire | Depends on the marriage or the choice | Côte d'Ivoire follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Cuba | Depends on the marriage or the choice | Cuba follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Democratic Republic of the Congo | Depends on the marriage or the choice | Democratic Republic of the Congo follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Djibouti | Depends on the marriage or the choice | Djibouti follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Dominica | Separate property | Dominica follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| El Salvador | Depends on the marriage or the choice | El Salvador follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Equatorial Guinea | Depends on the marriage or the choice | Equatorial Guinea follows the Spanish civil-code tradition, with customary marriages continuing alongside civil marriage. |
| Eritrea | Depends on the marriage or the choice | Eritrea has its own civil code for family law, and religious and customary rules are also recognised. |
| Eswatini | Depends on the marriage or the choice | Eswatini follows the Roman-Dutch tradition for civil marriages, and customary marriages follow customary rules. |
| Fiji | Separate property | Fiji follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Gabon | Depends on the marriage or the choice | Gabon follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Gambia | Depends on the marriage or the choice | Gambia has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Grenada | Separate property | Grenada follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Guatemala | Depends on the marriage or the choice | Guatemala follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Guinea | Depends on the marriage or the choice | Guinea follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Guinea-Bissau | Depends on the marriage or the choice | Guinea-Bissau follows the Portuguese civil-code tradition, in which the default is a community of what the spouses acquire during the marriage. |
| Guyana | Separate property | Guyana follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Haiti | Depends on the marriage or the choice | Haiti follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Honduras | Depends on the marriage or the choice | Honduras follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Iran | Personal law | In Iran family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Iraq | Personal law | In Iraq family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Jamaica | Separate property | Jamaica's Property (Rights of Spouses) Act gives each spouse an equal share in the family home, and other property is divided by what each contributed. |
| Kiribati | Separate property | Kiribati follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Kosovo | Depends on the marriage or the choice | Kosovo has a civil-code system of its own, in which the spouses have a legal regime unless they choose another by contract. |
| Kyrgyzstan | Joint (community) | Kyrgyzstan follows the model of the former Soviet family codes: what the spouses acquire during the marriage is joint property. |
| Laos | Depends on the marriage or the choice | Laos has its own family code, and religious or customary rules also apply to many marriages. |
| Lesotho | Depends on the marriage or the choice | Lesotho follows the Roman-Dutch tradition for civil marriages, and customary marriages follow customary rules. |
| Liberia | Depends on the marriage or the choice | Liberia has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Libya | Personal law | In Libya family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Liechtenstein | Depends on the marriage or the choice | Liechtenstein has a civil-code system of its own, in which the spouses have a legal regime unless they choose another by contract. |
| Madagascar | Depends on the marriage or the choice | Madagascar follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Malawi | Depends on the marriage or the choice | Malawi has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Maldives | Personal law | In Maldives family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Mali | Depends on the marriage or the choice | Mali follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Marshall Islands | Separate property | Marshall Islands follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Mauritania | Personal law | In Mauritania family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Mauritius | Depends on the marriage or the choice | Mauritius has a civil code of French origin, with common-law influences, and the property of the spouses depends on the regime they have. |
| Micronesia | Separate property | Micronesia follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Monaco | Depends on the marriage or the choice | Monaco has a civil-code system of its own, in which the spouses have a legal regime unless they choose another by contract. |
| Mongolia | Joint (community) | Mongolia follows the model of the former Soviet family codes: what the spouses acquire during the marriage is joint property. |
| Mozambique | Joint (community) | Mozambique's Family Law makes a community of acquests the default: what the spouses acquire during the marriage is shared. |
| Myanmar | Depends on the marriage or the choice | Myanmar has its own family code, and religious or customary rules also apply to many marriages. |
| Namibia | Depends on the marriage or the choice | Namibia follows the Roman-Dutch tradition for civil marriages, and customary marriages follow customary rules. |
| Nauru | Separate property | Nauru follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Nepal | Depends on the marriage or the choice | Nepal has its own family code, and religious or customary rules also apply to many marriages. |
| Nicaragua | Depends on the marriage or the choice | Nicaragua follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Niger | Depends on the marriage or the choice | Niger follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Oman | Personal law | In Oman family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Palau | Separate property | Palau follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Palestine | Personal law | In Palestine family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Panama | Depends on the marriage or the choice | Panama follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Papua New Guinea | Separate property | Papua New Guinea follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Republic of the Congo | Depends on the marriage or the choice | Republic of the Congo follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Rwanda | Depends on the marriage or the choice | Rwanda follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Saint Kitts and Nevis | Separate property | Saint Kitts and Nevis follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Saint Lucia | Separate property | Saint Lucia follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Saint Vincent and the Grenadines | Separate property | Saint Vincent and the Grenadines follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Samoa | Separate property | Samoa follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| San Marino | Depends on the marriage or the choice | San Marino has a civil-code system of its own, in which the spouses have a legal regime unless they choose another by contract. |
| São Tomé and Príncipe | Depends on the marriage or the choice | São Tomé and Príncipe follows the Portuguese civil-code tradition, in which the default is a community of what the spouses acquire during the marriage. |
| Senegal | Depends on the marriage or the choice | Senegal follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Seychelles | Depends on the marriage or the choice | Seychelles has a civil code of French origin, with common-law influences, and the property of the spouses depends on the regime they have. |
| Sierra Leone | Depends on the marriage or the choice | Sierra Leone has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Solomon Islands | Separate property | Solomon Islands follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Somalia | Personal law | In Somalia family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| South Sudan | Depends on the marriage or the choice | South Sudan has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Sudan | Personal law | In Sudan family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Suriname | Depends on the marriage or the choice | Suriname follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Syria | Personal law | In Syria family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Tajikistan | Joint (community) | Tajikistan follows the model of the former Soviet family codes: what the spouses acquire during the marriage is joint property. |
| Timor-Leste | Depends on the marriage or the choice | Timor-Leste follows a civil-code tradition in which the spouses can usually choose between sharing what they acquire and keeping their property separate. |
| Togo | Depends on the marriage or the choice | Togo follows the French civil-code tradition, with customary and Islamic marriages continuing alongside civil marriage. |
| Tonga | Separate property | Tonga follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Trinidad and Tobago | Separate property | Trinidad and Tobago follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Turkmenistan | Joint (community) | Turkmenistan follows the model of the former Soviet family codes: what the spouses acquire during the marriage is joint property. |
| Uganda | Depends on the marriage or the choice | Uganda has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Vanuatu | Separate property | Vanuatu follows the common-law tradition: each spouse generally owns what is in their own name, and the court divides property fairly on divorce. |
| Yemen | Personal law | In Yemen family law is based on Islamic law, under which each spouse keeps their own property and the wife is entitled to the mahr. |
| Zambia | Depends on the marriage or the choice | Zambia has civil, customary and, for Muslims, Islamic marriage side by side, and the property rules depend on which kind the couple have. |
| Zimbabwe | Depends on the marriage or the choice | Zimbabwe follows the Roman-Dutch tradition for civil marriages, and customary marriages follow customary rules. |
The main ways of sharing
- Community. What either spouse earns or acquires during the marriage belongs to both, whoever’s name is on it. What each owned before, and gifts and inheritances, usually stay personal.
- Gains shared at the end. Each spouse owns their own property during the marriage, but when it ends the gains made during it are compared and shared.
- Separate property. Each spouse keeps what is in their name. A court may still divide property on divorce, so separate ownership is not a guarantee of keeping everything.
- Personal law. In some countries the rules depend on the spouses’ religion, so the answer is not the same for every couple.
Marrying a foreigner?
- The rules of the country where you live, and where you first live after the wedding, can matter more than the country of the ceremony.
- A marriage contract signed before the wedding is the main way to set your own rules, and in many countries it must be notarised.
- In many European countries the spouses can choose which country’s law governs their property, in writing.
- Buying property abroad has its own limits for foreigners. See our guide on buying property abroad.
Take it further
The family and property rules of a European country in one PDF, with questions for a local lawyer.
Set the property rules before the marriage, in your own terms.
For couples who live together without marrying.
Marriage, divorce, custody and support, step by step.
Divide property and settle the terms in writing.
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