Security Rights in Movable Property in European Private Law
Seiten
2009
Cambridge University Press (Verlag)
978-0-521-10414-2 (ISBN)
Cambridge University Press (Verlag)
978-0-521-10414-2 (ISBN)
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union.
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.
Professor of German and European Private Law and Private International Law at Universität Würzburg, Germany.
Part I. Introduction and context: 1. Introduction Eva-maria Kieninger; 2. A labyrinth of creditors Willem J. Zwalve; 3. Security in movables in the United States Harry C. Sigman; 4. The English law of security Michael Bridge; 5. The European Bank for Reconstruction and Development's Secured Transactions project Frederique Dahan and John Simpson; Part II. The Case Studies; Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger; Indexes.
| Erscheint lt. Verlag | 19.3.2009 |
|---|---|
| Reihe/Serie | The Common Core of European Private Law |
| Mitarbeit |
Assistent: Michele Graziadei, George L. Gretton, Cornelius G. van der Merwe, Matthias E. Storme |
| Verlagsort | Cambridge |
| Sprache | englisch |
| Maße | 156 x 234 mm |
| Gewicht | 1200 g |
| Themenwelt | Recht / Steuern ► Allgemeines / Lexika |
| Recht / Steuern ► EU / Internationales Recht | |
| Recht / Steuern ► Privatrecht / Bürgerliches Recht ► Sachenrecht | |
| ISBN-10 | 0-521-10414-9 / 0521104149 |
| ISBN-13 | 978-0-521-10414-2 / 9780521104142 |
| Zustand | Neuware |
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