International reservation of title clauses : a study of Dutch, French and German private international law in the light of European law

著者

    • Rutgers, Jacobien W.

書誌事項

International reservation of title clauses : a study of Dutch, French and German private international law in the light of European law

Jacobien W. Rutgers

T.M.C. Asser, c1999

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注記

"Sold and distributed in North, Central and South America by Kluwer Law International"--T.p. verso

Originally presented as the author's thesis (doctoral)--European University Institute, Florence, Italy

Includes bibliographical references (p. 217-228) and index

内容説明・目次

内容説明

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. The author seeks the solution in private international law, since other means of addressing the problem, such as harmonization and unification of substantive law rules, have failed so far. This book is strong in its analysis of the various conflict of laws solutions and pioneering in how it deals with the question of the extent to which rules of private international law in this field must be in compliance with European law. The consequences of the various modes in which such compliance may be achieved are carefully analysed. This study is an important contribution to the understanding of European integration in a hitherto relatively neglected subject area and is suitable for a wide range of potential readers; both academics and practitioners in private international law and European law should find it of great interest.

目次

Substantive Law.- Private International Law and International Jurisdiction.- The Influence of European Law on the Conflict Rules Governing a Reservation of Title Clause.- Conclusions.

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