Conflict of Laws European Union Law

Rome I and Rome II in Practice

By Emmanuel Guinchard
Intersentia Publishers October 2020

Specifications

ISBN-13
9781780686714
Publisher
Intersentia Publishers
Publication
October 2020
Format
Hardback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

This book is devoted to the applicable law to contractual and non-contractual obligations in the European Union. The Rome I and II Regulations provide uniform conflict of laws rule in order to avoid undue forum-shopping. In theory all national courts of EU Member States (excluding Denmark) apply the same rules determining the applicable law. Rome I and II in Practice examines whether the theory has been put into practice and assesses difficulties that may have arisen in the interpretation and application of these Regulations. Such study appears invaluable as the Rome I and II Regulations may be seen as a critical stepping stone towards the construction of a true and far-reaching European Private International Law.

Providing clear and detailed insights into the national case law of most EU Member States, as well as the case-law of the Court of Justice, and followed by a comparative analysis, this book is a valuable resource for practitioners, the judiciary, and academics who are interested in understanding how EU law is applied on national level.

Table of Contents

Introduction - Emmanuel Guinchard
Questionnaire for the National Reports
Court of Justice of the European Union
Austria and Germany
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
France
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
The Netherlands
Poland - Marcin Czepelak
Portugal
Slovakia
Slovenia
Spain
United Kingdom
Conclusion - Emmanuel Guinchard
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