Alimony obligations of spouses and ex-spouses: comparative legal analysis of the legislation of Kazakhstan and some foreign countries

Abstract

The article is devoted to the comparative legal analysis of the legal regulation of alimony obligations of spouses and ex-spouses in Kazakhstan and in some developed foreign countries, in particular in Germany, France, the UK, the USA. Based on the research and analysis of the legislation of the Republic of Kazakhstan and foreign countries, the current problems of the material maintenance of spouses and former spouses both during marriage and after the dissolution of marriage are considered. The features of the legislative regulation of alimony obligations of spouses in the countries included in the Anglo-Saxon and continental legal systems are analyzed. Attention is focused on the problems of determining the amount of alimony, the term and procedure for the payment of alimony, as well as the grounds for termination of the alimony obligation. The purpose of the study is to conduct a comparative legal analysis of the legal regulation of alimony obligations of spouses and former spouses in the Republic of Kazakhstan and in some countries of the world and on the basis of the study to identify shortcomings of legal regulation, to determine further ways to improve domestic legislation. Based on the study of legislation and law enforcement practice on the settlement of disputes on material maintenance between spouses and former spouses, the authors make proposals aimed at improving the family legislation of the Republic of Kazakhstan.