3 edition of Harmonisation of Substantive and International Private Law (Internationalrechtliche Studien) found in the catalog.
Harmonisation of Substantive and International Private Law (Internationalrechtliche Studien)
by Peter Lang Pub Inc
Written in English
|Contributions||Ole Lando (Editor), Ulrich Magnus (Editor), Monika Novak-Stief (Editor)|
|The Physical Object|
|Number of Pages||228|
International Reservation of Title Clauses:A Study of Dutch, French and German Private International Law in the Light of European Law. Editors: Rutgers, Jacobien (Ed.) Buy this book such as harmonization and unification of substantive law rules, have failed so far. The book is strong in the analysis of the various conflict of laws solutions. HARMONISATION OF SECURITIES LAW 9) Harmonisation initiatives Introduction the case for harmonisation three levels of challenge Global initiatives introduction recommendations UNIDROIT instrument on substantive law Hague convention on private international law European harmonisationAuthor: Matthias Haentjens.
Traditional rules of private international law on jurisdiction are based on geographical connecting factors, such as domicile of the parties, which are sometimes not applicable in the Internet. Some other connecting factors, such as the place of contracting, the place of performance, the place where an establishment is situated, etc, are not so. The central research question is whether it is desirable, and if so, possible to aim for the harmonisation or unification of private international law rules in this specific field of non-marital registered relationships. The introductory chapter of the book finishes with some theoretical considerations on the problem of characterisation.
Also available as an e-book Traditionally, conflict of law rules designate only national substantive law as the applicable law. Many unifying and harmonizing substantive law instruments of both Author: Katharina Boele-Woelki. 1. Introduction The theory that I shall seek to elaborate here puts considerable emphasis on the emerging discourse of European private law, the interdependence of rules of private international law and civil procedure, the harmonization of private international law, and the important global framework for conventions in the area of private international law.
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The ancestors & descendants of Henry William Von Hollen (Heinrich Wilhelm von Hollen), 1811-1883, & his wife Doris Rademacher, 1830-1919, of Bexhövede, Altuneberg, Niedersachsen, Germany (the former Kingdom of Hanover), and immigrants to South Carolina
: Angleichung des materiellen und des internationalen Privatrechts in der EU- Harmonisation of Substantive and International Private Law (Internationalrechtliche Studien) (English and German Edition) (): Magnus, Ulrich, Novak-Stief, Monika, Lando, Ole: Books.
private international law, choice of law in contract, uniform law, harmonisation, EU, Commisson's Proposal for a Regulation on a Common European Sales Law, CESL Keywords [sv] internationell privaträtt, uniform rätt, harmonisering, EU, kommissionens förslag till Author: Carolina Saf. The book is an impressive collection of knowledge and ideas, containing 45 contributions by 50 scholars from around the world on various aspects of private international law as well as the harmonisation or reform of substantive private by: 3.
The advantages of harmonisation are obvious – decrease the economic costs involved in management of resources and it can increase the ease of trade.4 The advantages of a single system of law have long been recognised 1 BA/LLB (Hons) (Griffith), GDLP (Griffith) MCL (Adelaide/Mannheim), LLM (Griffith), Grad.
Cert. Arts (UNE), Law Lecturer Author: Ross Ashcroft. It is clear that international sales are in need of a legal system that can transcend national boundaries and that can function without the need to resort to rules of private international law.
Harmonisation of Substantive and International Private Law book of the substantive law is a possible answer to this problem. A number of organisations have been created with the goal of harmonising.
Harmonisation of the rules of European Private International Law.3 Private Law in general tends to organise social relationships between private citizens or non-State organisations. Private international law is made up of mechanisms that facilitate the settlement of international disputes between the same.
It answers three questions: 1. Two articles are dedicated to the integration of private law in the European Community: The paper on “Conflict of laws and the harmonization of substantive private law in the European Union” investigates the increasingly complex interrelation between private international law as the traditional means of solving cross-border conflicts of laws, and the growing body of harmonized or even unified substantive law.
law, and that the real purpose of the private international law is the coordination of legal systems, it seems more logical to say that such private European international law, should be borrowed from the these two traditions and have the characteristics of a mix Size: KB.
Introduction. Private international law consists of principles and rules for dealing with legal disputes that have a foreign element: for example, a cross-border divorce case, or transnational commercial dispute.
In England and Wales, the terms 'private international law' and 'conflict of laws' are interchangeable, and the subject encompasses choice of law, the court's jurisdiction and the Author: Hester Swift. Private international law - I.
The Issues able rules • Harmonisation of private law rules offers limited results • E.g. art. 9 EU Directive on late payment in commercial transactions (/7): MS should enforce retention of title clauses but only “in conformity with the applicable nationalFile Size: 1MB.
Traditionally, conflict of law rules designate only national substantive law as the applicable law. Many unifying and harmonizing substantive law instruments of both States and non-State organizations, however, are designed specifically for application to cross-border by: 8.
This chapter deals with the interaction between procedural law and substantive private law in the context of a partially harmonised but mainly non harmonised substantive law.
It also discusses civil proceedings dealing with matters not exclusively governed by domestic : Matthias Edward Storme. The Codification of Private International Law in Europe: Could the Community Learn as family law, where substantive harmonisation cannot currently be envisaged because the private international law should borrow from both traditions and therefore display characteristics of.
mixedness. As Lord Mance wrote inPrivate International File Size: KB. The Meaning of Harmonisation in the Context of European Union Law – a Process in Need of Definition Eva J. Lohse Theory and Practice of Harmonisation in the European Internal Market Isidora Maletic International Competition Law Harmonisation and The WTO: Past, Present and Future Jurgita Malinauskaite Cited by: 8.
A range of international and European Union legal instruments exert influence on the national civil procedure rules of European Union member states. Some specifically aim for the harmonisation of national procedural law across Europe, while others primarily focus on facilitating cross-border litigation, enforcing rights or setting minimum standards.
Germain’s Transnational Law Research: A Guide for Attorneys, New York, Transnational Publishers, updated annually. Chapter II: Foreign and International Law: Substantive Issues - Two sections in this chapter deal with the harmonization of international law: 03, Unification of Laws, andUnification of Private International Law in the U.S.
Private international law on marriages and legal dissolution of marriages (divorce) Main article: Conflict of marriage laws. In divorce cases, when a court is attempting to distribute marital property, if the divorcing couple is local and the property is local, then the court applies its domestic law lex fori.
Private international law is opposite to public international law which refers to the rights and interaction of countries.
Private international law is focused on the rules, called choice of law rules, used to select foreign law. Private international law is applied for example when a contract is signed in one country and is sent to another. Public law Private law (Private International Law; Uniform Substantive Law) III.
Lex Mercatoria. The above classification has merits in that it sheds light on the multiplicity of sources of international trade law. The pitfalls of this classification are the emphasis of state-made law and the support for so-called hard law provisions. Buy EU Private International Law: Harmonization of Laws (Elgar European Law series) by Stone, Peter (ISBN: ) from Amazon's Book Store.
Author: Peter Stone. The rules of substantive law relating to the reservation of title clause differ from country to country. This book addresses problems which may arise if a reservation of title clause is employed within international transactions, especially transactions between Germany, France, and the Netherlands.Harmonization of private international law by the E.E.C.
London: Institute of Advanced Legal Studies, University of London, (OCoLC) Material Type: Internet resource: Document Type: Book, Internet Resource: All Authors / Contributors: Kurt Lipstein; University of London. Institute of Advanced Legal Studies. Since the Commission on European Family Law was established inharmonisation of substantive family law in Europe has been the subject of heated debate.
The impossibility and undesirability of harmonising family law was long taken for by: 3.