Dispute Resolution and Conflict of Laws

As European conflict of laws principles, the Rome Regulations have largely replaced national regulations and are directly applicable in every EU Member State. Accompanied by the increasing number of cross-border issues in Europe, it is indispensable for national legal consultation to be acquainted with the relevant conflict of laws rules. The new European conflict of laws principles also have a major effect on classical core areas of civil law, including contractual law, criminal law and law of obligation. The new commentary analyses article-by-article all relevant European regulations:

• Rome I and Rome II
• Brussels Ibis Regulation
• Service Regulation
• Taking of Evidence Regulation
• Enforcement Order Regulation
• European Insolvency Regulation

In addition, the commentary pays attention to on conventions of international arbitration:

• New York Convention
• UNCITRAL-ML

The commentary focuses expressly on the recast of the Brussels I Regulation and the European Insolvency Regulation as well as on the relationship between the general conflict of laws rules and the national law of the Member States. It takes account of disputes before national courts such as arbitration proceedings.