Question juridique clé
Whether a modification of interim maintenance measures under Art. 145 ZGB may be made retroactive beyond the filing date of the request.
Solution extraite
As a rule, modification takes effect only from the filing date; further retroactivity requires special circumstances.
Motifs extraits
The parties must be able to rely on the provisional measure until it is challenged. Greater retroactivity is exceptional and requires special reasons such as an objectively justified or culpably caused inability to clarify finances.