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Rome I and Rome II in Practice

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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.

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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