FLiP 33 - Should I Divorce in England or France? Comparing Divorce Laws and Financial Remedies
FLiP Talks: Divorce, Separation & Family Law
Release Date: 10/13/2025
FLiP Talks: Divorce, Separation & Family Law
In this episode, Elizabeth Hicks is joined by Oren Weinberg to compare divorce and financial claims in England and Wales with the system in the province Ontario, Canada. The discussion focuses on issues relevant to individuals with connections to both jurisdictions. Looking at both jurisdictions, they cover: Jurisdiction for divorce, including domicile and residency Financial claims on divorce Maintenance claims Claims available to non-married couples Pre- and post-nuptial agreements Key differences between England and Wales and Ontario, Canada. About the speakers: is a leading expert in...
info_outlineFLiP Talks: Divorce, Separation & Family Law
In this episode, David Allison is joined by Lavanya Regunathan Fischer to compare divorce and financial claims in England and Wales with the system in India. The discussion focuses on issues relevant to individuals with connections to both jurisdictions. Looking at both jurisdictions, they cover: Jurisdiction for divorce Grounds for divorce and the concept of "irretrievable breakdown" of the marriage Religious vs secular marriage systems in India Financial claims on divorce Pre- and post-nuptial agreements Child arrangements Claims available to non-married couples * see disclaimer at...
info_outlineFLiP Talks: Divorce, Separation & Family Law
David Allison and Jeremy Johnson In this episode, David Allison is joined by leading barrister Jeremy Johnson to compare divorce and financial claims in England and Wales with the system in New Zealand. The discussion focuses on issues relevant to individuals with connections to both jurisdictions. Looking at both jurisdictions, they cover: • Jurisdiction for divorce, including domicile and residency • Financial claims on divorce • Maintenance claims • Claims available to non-married couples • Pre- and post-nuptial agreements • Key differences between England and Wales and...
info_outlineFLiP Talks: Divorce, Separation & Family Law
In this episode, David Allison is joined by leading attorney Katharine Maddox to compare divorce and financial claims in England and Wales with the system in the state of Virginia. The discussion focuses on issues relevant to individuals with connections to both jurisdictions. Looking at both jurisdictions, they cover: Jurisdiction for divorce, including domicile and residency Financial claims on divorce Maintenance claims Claims available to non-married couples Pre and post-nuptial agreements Key differences between England and Wales and Virginia *Update: Effective from July 1, 2026:...
info_outlineFLiP Talks: Divorce, Separation & Family Law
In this episode and break down the legal steps and practical considerations every parent must know when considering a move abroad with children. This conversation will help you make informed, confident decisions for your family’s future. Their conversation covers: • What are the rules surrounding travelling abroad with children on a short and a long term basis? • What applications can be made to deal with any dispute? • What does the process look like once an application is made? • How do you decide which country deals with any dispute? • What factors will be considered by the...
info_outlineFLiP Talks: Divorce, Separation & Family Law
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...
info_outlineFLiP Talks: Divorce, Separation & Family Law
Helen Greenfield and Chloe Oudiz meet to discuss international, long-distance co-parenting. With insights from their respective experiences, they provide practical tips on how to approach long distance co-parenting. Their conversation covers: Jurisdiction issues which come to light upon separation Who keeps the passports Contact and time spent with the “long distance” parent Parental responsibility Communicating as co-parents The introduction of a new partner The benefit of mediation Top tips for those thinking of embarking on long-distance co-parenting About the speakers: Helen...
info_outlineFLiP Talks: Divorce, Separation & Family Law
Precis: Kara Swift and Lucy Taylor meet again to discuss financial planning after separation or divorce. Following their recent conversation on how to move from financial vulnerability to financial resilience, Kara and Lucy discuss finances following separation and divorce. As they explain, the implications of the numbers at the outset can be huge and if you do not have an understanding of the family’s finances it can be dauting. Professionals like Kara and Lucy can help you move forward with confidence. With insights from their respective experience, they provide practical tips...
info_outlineFLiP Talks: Divorce, Separation & Family Law
With the context that only 53% of women feel financially independent, Kara Swift invited Lucy Taylor to discuss her mission to encourage women to make sure they are financially future proofed and strong. In a conversation that focusses on how to move from financial vulnerability to financial resilience, they discuss: The division of decisions within a relationship The difference between being part of a married or unmarried couple How Cohabitation Agreements can provide financial certainty for unmarried women How a pre-nuptial agreement can set the tone for a financially healthy marriage...
info_outlineFLiP Talks: Divorce, Separation & Family Law
and discuss how to protect children’s mental health when their parents are in family court proceedings, or any process where a third party needs to make a decision for them, such as arbitration. Whether proceedings are about the children themselves, or the parents’ finances, Daniel and Jo agree that both the parents and the lawyers should do as much as possible to insulate children from the process and stress associated with it. They talk about direct ways to look out for children, as well as practical strategies to help parents protect themselves and support everyone’s...
info_outlineDivorcing 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).