Le transfer de la propriété dans la vente d'objets mobiliers corporels en droit comparé PDF Download

Author: Michel Waelbroeck
Publisher:
ISBN:
Category :
Languages : fr
Pages : 246

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Author: Wolfgang Faber
Publisher: Walter de Gruyter
ISBN: 386653700X
Category : Law
Languages : en
Pages : 281

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Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.

Author: Michel WAELBROECK
Publisher:
ISBN:
Category :
Languages : fr
Pages : 246

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Author: Michel Waelbroeck
Publisher:
ISBN:
Category : Acquisition of property
Languages : fr
Pages : 260

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Author: Eva-Maria Kieninger
Publisher: Cambridge University Press
ISBN: 1139454757
Category : Law
Languages : en
Pages : 827

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For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.

Author: Jost Delbrück
Publisher: Duncker & Humblot
ISBN: 9783428456284
Category : Law
Languages : en
Pages : 554

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Inhaltsverzeichnis Inhalt: H.G. Petersmann, The Operations of the World Bank and the Evolution of its Institutional Functions since Bretton Woods (1944-84) - B. Vitanyi, La relative gratuité de l'utilisation des voies d'eau internationales, est-elle devenue une règle coutumière? - J.H. Wolfe, The Mississippi Boundary Case. The Role of International Law in Federal-State Relations - J. Fisch, The Falkland Islands in the European Treaty System 1493-1833 - E.D. Graue, Recognition and Enforcement of Foreign Security Interests under Domestic Conflict Rules - H. Meyrowitz, Le statut des.

Author: Jan H Dalhuisen
Publisher: Bloomsbury Publishing
ISBN: 1509925805
Category : Law
Languages : en
Pages : 851

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This is the seventh edition of the leading work on transnational and comparative commercial, financial, and trade law, covering a wide range of complex topics in the modern law of international commerce, finance and trade. As a guide for students and practitioners it has proven to be unrivalled. The work is divided into three volumes, each of which can be used independently or as part of the complete work. Volume 2 deals with the transnationalisation of contract; movable and intangible property law; and the transformation of the models of contract and movable property in commercial and financial transactions between professionals in the international flow of goods, services, money, information, and technology. In this transnational legal order, the emphasis in the new law merchant or modern lex mercatoria of contract and movable property turns to risk management, asset liquidity, and transactional and payment finality. Common law and civil law concepts are compared and future directions indicated. The potential, effects, and challenges of the blockchain are noted, so far especially for the carriage of goods by sea. All three volumes may be purchased separately or as part of a single set.

Author: Wolfgang Faber
Publisher: Walter de Gruyter
ISBN: 3866539223
Category : Law
Languages : en
Pages : 737

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This excellent series presents comparative study, analysis and evaluation of 28 European legal systems in the field of transfer of movables. Major topics are the notion of ownership, the derivative acquisition of ownership (e.g. by a sales contract), the good faith acquisition of ownership and other property rights, the multiple sale of the same movable, the protection of possession, positive (acquisitive) prescription, and processing and consolidation. The work is based on comprehensive country reports (which are to be published) on the relevant legal rules in Europe and has the drafting and publication of text proposals of uniform European rules - with commentary and comparative notes - as its primary goal. It intends to influence the future development of European private law on the EU level. This fourth volume of the series presents "up-to-date" national reports of France Belgium Bulgaria Poland Portugal

Author: Pavel Kalenský
Publisher: Springer Science & Business Media
ISBN: 9401195900
Category : Law
Languages : en
Pages : 308

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to Seeking the answer to the three basic questions of contempo rary private international law, I also deemed it essential to out line to the reader the historical development of the different concepts of this particular branch of law, for without the know ledge of this history it is impossible to understand the contempo rary problems. The fact that private international law oscillates between public international law and substantive municipal law as it is applied in individual countries creates considerable problems in both theory and practice. I have tried to deal with these problems in the third part of my study, concerning "universa lism" and "nationalism" in the doctrine of private international law, as well as in its fourth part, which is devoted to the object and nature of this law and its place in the overall system of law. The character of private international law, ensuing from the plurality of municipal laws - which also characterize the origin and existence of comparative jurisprudence - in spired me to produce the fifth part of this study, which prima rily tries to expJain the theoretical problems of comparative jurisprudence but does so - defining its objectives and possibili ties - in order to underline at the same time its role in private international law and in the law of international trade.

Author: Théophile M. Margellos
Publisher:
ISBN:
Category : Conditional sales
Languages : fr
Pages : 592

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