German Article on the Applicable Law concerning Maintenance Obligations

Rolf Wagner (Berlin) gives an overview on new developments concerning the law applicable regarding maintenance obligations in the German legal journal FamRZ 2006, 979 et. seq. He addresses two new measures which deal with this field of law: On the one hand the plans of the Hague Conference to draft a new Convention on Maintenance Obligations which is planned to replace the two Hague Conventions from 1958 and 1973, and on the other hand the Proposal for a Council Regulation on jurisdiction, applicable law, recognition and enforcement of decisions and cooperation in matters relating to maintenance obligations, COM(2005) 649 final. Wagner compares the conflict of law rules of both drafts and attends to the relationship between these two instruments.