169 research outputs found
Unification and harmonization of international commercial law: interaction or deharmonization?/ ed. by Morten Fogt.
No full textBased on the conference held at the University of Aarhus in October 2009.Includes bibliographical references and index.The concept of unificationa and harmonizaton / Hans Henrik Edlund -- Harmonization of European private law: what can Roman law teach us; what can it not? / Pascal Pichonnaz -- The impact of the UN CISG on the harmonization of national and international non-conformity rules / René F. Henschel -- Private international law in the process of harmonization of international commercial law: the 'ugly duckling'? / Morten M. Fogt -- Developing global transnational harmonization procedures for the twenty-first century: the accelerating pace of common and civil law convergence-first decade update / Louis F. Del Duca -- De facto harmonization by means of party autonomy and model contract clauses (Lex Mercatoria) -- Harmonizaton and unification of law by the means of general principles / Ulrich magnus -- Uniformity and harmonization by case law: the CISG and the global jurisconsultorium / Camilla Baasch Andersen -- Pragmatism in Nordic contract law: origins, characteristics, and consequences / Mads Bryde Andersen -- European harmonization and the Draft Common Frame of Reference / Eric Clive -- Harmonization of international commercial law within the commonweatlh and the independent States / Alexander Trunk -- CESL and its precursors / Ole Lando -- Final panel discussion: the effect of multiple means of harmonization: interaction or deharmonization? / chair: Eric Clive.1 online resource (xv, 282 pages
International Property Law and Territoriality
No full textThe ongoing work in the area of private international law of property, principally under the auspices of EAPIL and GEDIP in the European continent, may form the basis for a future EU legal instrument on the applicable law to international property cases. Against that framework, this paper examines whether the principle of territoriality as the main vector may withstand the surge of a wide range of novel assets and a diversified property law landscape. It proposes that the hegemony of the lex situs should be revisited
The Law Applicable to (Digital) Transfer of Digital Assets : The Transfer of Cryptocurrencies via Blockchains
No full textCivil Law Consequence of Corruption in Danish Law – The Oil-for-Food Programme Cases and Beyond
No full textThe Knowledge Test Under the CISG - A Global Threefold Distinction of Negligence, Gross Negligence and De Facto Knowledge
No full textN/
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Private international law in an era of change /
No full text"This timely book examines the complex challenges arising in modern private international law (PIL). The book brings together leading practitioners and scholars to consider the future of this dynamic area of law. Covering key themes including digitalisation, European civil cooperation, the codification of PIL, and judicial cooperation, the book explores the many forces shaping PIL at a global, regional and domestic level. Authors examine the processes of both harmonisation and fragmentation of PIL, and highlight the continuing importance of territoriality. They focus on areas which have recently undergone transformation, such as family law, the law of succession, blockchain, smart contracts, and property law. Through showcasing the developments that PIL has already undergone and highlighting areas for further advancement, the book provides a well-rounded picture of the relevance and effectiveness of PIL in today's world. Private International Law in an Era of Change is an essential resource for academics and practitioners of PIL, including those with an interest in arbitration and dispute resolution, family law and international commercial law"-
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Choices, limits and consequences of harmonisation of commercial law ::the circle of law harmonisation /
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