EU law and private international law : the interrelationship in contractual obligations /
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Author / Creator: | Kuipers, Jan-Jaap. |
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Imprint: | Leiden ; Boston : Martinus Nijhoff Publishers, 2012. |
Description: | 1 online resource (x, 371 pages) |
Language: | English |
Series: | Nijhoff studies in EU law ; v. 1 Nijhoff studies in EU law ; v. 1. |
Subject: | |
Format: | E-Resource Book |
URL for this record: | http://pi.lib.uchicago.edu/1001/cat/bib/11124925 |
Summary: | The Rome I Regulation on the Law Applicable to Contractual Obligations has unified the conflict of laws rules of the Member States. The influence of the European Union upon Private International Law goes beyond positive harmonisation however. There is a certain tension between European law and PIL. European law is concerned with whether the imposition of a rule constitutes a restriction to the internal market whereas PIL does not seek to neutralise the disadvantages that result from differences between national laws but instead tries to locate the geographical centre of the legal relationship. The present book attempts to identify the methodological disharmony between the two legal disciplines in the regulation of cross border contracts and proposes suggestions to enhance their mutual understanding. |
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Physical Description: | 1 online resource (x, 371 pages) |
Bibliography: | Includes bibliographical references and index. |
ISBN: | 9789004206724 9004206728 9789004206731 9004206736 1283356643 9781283356640 9786613356642 6613356646 |