两岸三地夫妻财产制度比较研究国际法学专业论文.docxVIP

1 1 2 2 Abstract Matrimonial property system, also known as marital property system is a kind of defines the property relationship between the couple of general laws, which in modern marriage and family takes a more and more important role in the marriage and family law, but also an indispensable part of. As of 2011July by the Supreme Peoples Court issued on the application of marriage law of the peoples Republic s interpretation of several issues ( three), which let us to the husband and wife property has some new thinking. Especially in China, marriage and love is always the most ancient and most beautiful, to the development of todays society, marriage and family for the wealth of production and management also will produce tremendous influence. Marriage and family relations is not merely the relationships within the family, but involves many social relations, can be said that marriage family involved in a series of social relationship with our daily life, and due to the economy, culture, history, tradition and other factors, the mainland, Hong kong area, Taiwan area in the marriage law in the field of prescribed somewhat difference, matrimonial property system is one of the problems. This paper based on the three sides, namely the mainland, Hong kong area, Taiwan area of the marital property system as the research object, trying on three sides of the matrimonial property system of logic and content analysis, through a comparative study, analysis in three couples property system about the relation and the difference. This paper is divided into three parts. The first part is mainly on the basis of theories of marital property system. The main part of marital property system from the connotation, value and the origin of three aspects, introduced the concept of marital property system, characteristics, content and types of legislation, expounds the marital property system in the application of the principle of three sides, list of marital property system origin, t