Download or read book National Reports on the Transfer of Movables in Europe written by Wolfgang Faber and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book National Reports on the Transfer of Movables in Europe written by Wolfgang Faber and published by Sellier European Law Pub. This book was released on 2011 with total page 667 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the fifth volume of a series of national reports on basic issues concerning the acquisition and loss of ownership of movable assets. The series covers 28 European legal systems. Starting with general property law issues like the concepts of ownership and possession employed in the respective legal systems, and the related means of protection, the reports primarily deal with the `derivative' transfer of ownership, but extend to good faith acquisition from a non-owner, acquisitive prescription, processing and commingling, and further related issues. The reports provide the reader with detailed information about the respective rules, case law and legal literature, prepared by national property law experts. These reports are a starting point for further comparative research in property law and also a tool for practitioners searching for information on foreign legal systems.

Download or read book National Reports on the Transfer of Movables in Europe written by Wolfgang Faber and published by Sellier European Law Pub. This book was released on 2011 with total page 723 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the fourth volume of a series of national reports on basic issues concerning the acquisition and loss of ownership of movable assets. The series covers 28 European legal systems. Starting with general property law issues like the concepts of ownership and possession employed in the respective legal systems, and the related means of protection, the reports primarily deal with the `derivative' transfer of ownership, but extend to good faith acquisition from a non-owner, acquisitive prescription, processing and commingling, and further related issues. The reports provide the reader with detailed information about the respective rules, case law and legal literature, prepared by national property law experts. These reports are a starting point for further comparative research in property law and also a tool for practitioners searching for information on foreign legal systems.

Download or read book National Reports on the Transfer of Movables in Europe written by Wolfgang Faber and published by . This book was released on 2010 with total page 713 pages. Available in PDF, EPUB and Kindle. Book excerpt: HauptbeschreibungThis excellent series presents comparative study, analysis and evaluation of 28 European legal systems in the field of transfer of movables. Major topics are - the notion of ownership, - the derivative acquisition of ownership (e.g. by a sales contract), - the good faith acquisition of ownership and other property rights, - the multiple sale of the same movable, - the protection of possession, positive (acquisitive) prescription, and- processing and consolidation. The work is based on comprehensive country reports (whi.

Download or read book National Reports on the Transfer of Movables in Europe written by Wolfgang Faber and published by . This book was released on 2010 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This excellent series presents comparative study, analysis and evaluation of 28 European legal systems in the field of transfer of movables. Major topics are - the notion of ownership, - the derivative acquisition of ownership (e.g. by a sales contract), - the good faith acquisition of ownership and other property rights, - the multiple sale of the same movable, - the protection of possession, positive (acquisitive) prescription, and - processing and consolidation. The work is based on comprehensive country reports (which are to be published) on the relevant legal rules in Europe and has the drafting and publication of text proposals of uniform European rules - with commentary and comparative notes - as its primary goal. It intends to influence the future development of European private law on the EU level. This fifth volume of the series presents "up-to-date" national reports of - Sweden - Norway and Denmark - Finland - Spain.

Download or read book National Reports on the Transfer of Movables in Europe Austria Estonia Italy Slovenia written by Wolfgang Faber and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book National Reports on the Transfer of Movables in Europe Germany Greece Lithuania Hungary written by Wolfgang Faber and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book National Reports on the Transfer of Movables in Europe England and Wales Ireland Scotland Cyprus written by Wolfgang Faber and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book H van Kruiningen written by and published by . This book was released on 1964 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Rules for the Transfer of Movables written by Wolfgang Faber and published by Walter de Gruyter. This book was released on 2009-04-27 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.

Download or read book Transfer of title concerning movables National report Germany written by J. Michael Rainer and published by Peter Lang Publishing. This book was released on 2006 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a general introduction to the problems of ownership and transfer of title considering movables in the European Union. Common solutions for a legal unification in Europe are taken into consideration, followed by national reports from Estonia, Italy, Poland, Portugal, Scotland, Slovenia, and Spain.

Download or read book Rules for the Transfer of Movables written by Wolfgang Faber and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Comparative research in the area of property law is gaining importance. Against the background of the current discussion of developing model rules, aimed at facilitating European private law harmonisation, and of ongoing law reform projects in a number of EU Member States, this volume addresses key issues in the field of the transfer of corporeal movable property.

Download or read book The Future of European Property Law written by Sjef Erp van and published by Walter de Gruyter. This book was released on 2012-05-29 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: European integration has a growing impact on the property law systems of the EU Member States. The tensions which can be seen are considerably greater than in other areas of private law, given the technically complex and mandatory nature of property law. In this book current developments in European property law (particularly the Draft Common Frame of Reference) are analysed and evaluated, focussing on secured transactions and mortgage law. With contributions by academic and practicing lawyers, containing: Transfer of ownership and good faith acquisition: the rules in the Member States and in Book VIII of the DCFR Secured transactions and the DCFR Registration of intellectual property rights Trusts - from a Common and a Civil lawyer’s perspective The border area between property law and contract law: securities

Download or read book Comparative Law and the Quest for Optimal Rules on the Transfer of Movables for Europe written by Arthur F. Salomons and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The drafters of Book VIII Draft Common Frame of Reference (DCFR) have devoted an impressive amount of time and energy in collecting and publishing comparative data with regard to the existing property law within all Member States of the European Union, and in particular with regard to the subject matter of that Book: acquisition and loss of ownership of movables. This in itself suggests that comparative research played an important role in the drafting process, and this impression is enhanced by the abundance of comparative references and notes in the official Comments to Book VIII. However, the fact that the drafters made an extensive study of the relevant property law of every European legal system does not imply per se that the outcome of their comparative research was taken as guiding in the establishment of the DCFR rules. In order to gain a better insight into the character of the rules of Book VIII, this contribution seeks to answer the question whether comparative arguments really weighed heavily in the drafting of Book VIII: is the 'comparative activism' of its drafters a manifestation of a determination that common or even majority solutions should be the basis of the model rules to be proposed, or did the drafters feel free to propose novel rules even if these were contrary to what applies in most European countries, according to the comparative data they collected and presented themselves? To find out to what extent the choices of the drafters were influenced, if not determined, by their comparative research, it would be helpful to know what comparative methodology they followed. On this, we are told by them that the functional approach of Zweigert and Kötz can hardly be used in property law, for lack of functionally similar solutions, but as a comparative introduction to Book VIII is lacking, the question what other method could take its place is not answered. Therefore, another course of action was needed in order to be able to answer the above mentioned question. This course was found by first of all collecting the scattered general remarks by the principal drafters of Book VIII on the role of their comparative research, and by secondly analyzing what kind of comparative arguments the drafters actually included in the Comments to the provisions of that Book. The results of this approach are as follows. The principal drafters' various publications on the work of the Working group responsible for the drafting of Book VIII DCFR seem to indicate that they gradually began to attach less importance to comparative arguments as the project progressed. Initially (in 2007), it was argued that the information in the National reports was 'vital to our project' and 'the most important basis for our work'. One year on, the Reports were indicated as 'a basis for the working group's own comparative research.' Finally, in 2011, the drafters called the comparative survey 'a main source of inspiration.' It may be that this change of tone is a reflection of a development in the way the drafters perceived the role of other arguments, in particular those based on policy decisions; such a development could well have been the result of the debates on the proposals of the Working group with the members of the Study group. But whatever the cause, a confirmation of the fact that such a development indeed occurred can be found in the Introduction to the final publication, in 2011, of the texts of and Comments and Notes to the provisions of Book VIII. Referring to the 'remarkable differences to be found in European property law regimes' it is stated that 'most articles were drafted according to policy decisions.' The impression is inescapable that comparative arguments gradually had to give way to policy arguments, or at least that the drafters wanted or felt compelled to give this impression. However, none of this is reflected in the Comments to the 29 Articles of the first three Chapters of Book VIII. The drafters indicated in a very large number of instances to have followed common or majority solutions. An explicit rejection of a majority solution occurred in only two instances of little importance. Only when common or majority solutions were absent, the drafters seem to have been more inclined to create novel solutions than to look for leads in the available comparative data. In the handful of instances where the drafters adopted a minority solution, this concerned rules on topics where the European legal systems are strongly divergent (notably good faith acquisition). We must conclude from the Comments that, even if the principal drafters themselves gradually began to convey a different impression, comparative arguments played an important, often even decisive role in the drafting of the rules of Book VIII. If so, these rules are even more firmly rooted in current European property law than is often assumed.

Download or read book France Belgium Bulgaria Poland Portugal written by Wolfgang Faber and published by Walter de Gruyter. This book was released on 2011-02-28 with total page 737 pages. Available in PDF, EPUB and Kindle. Book excerpt: This excellent series presents comparative study, analysis and evaluation of 28 European legal systems in the field of transfer of movables. Major topics are the notion of ownership, the derivative acquisition of ownership (e.g. by a sales contract), the good faith acquisition of ownership and other property rights, the multiple sale of the same movable, the protection of possession, positive (acquisitive) prescription, and processing and consolidation. The work is based on comprehensive country reports (which are to be published) on the relevant legal rules in Europe and has the drafting and publication of text proposals of uniform European rules - with commentary and comparative notes - as its primary goal. It intends to influence the future development of European private law on the EU level. This fourth volume of the series presents "up-to-date" national reports of France Belgium Bulgaria Poland Portugal

Download or read book The Netherlands Switzerland Czech Republic Slovakia Malta Latvia written by Wolfgang Faber and published by Walter de Gruyter. This book was released on 2010-12-23 with total page 599 pages. Available in PDF, EPUB and Kindle. Book excerpt: This excellent series presents comparative study, analysis and evaluation of 28 European legal systems in the field of transfer of movables. Major topics are - the notion of ownership, - the derivative acquisition of ownership (e.g. by a sales contract), - the good faith acquisition of ownership and other property rights, - the multiple sale of the same movable, - the protection of possession, positive (acquisitive) prescription, and - processing and consolidation. The work is based on comprehensive country reports (which are to be published) on the relevant legal rules in Europe and has the drafting and publication of text proposals of uniform European rules - with commentary and comparative notes - as its primary goal. It intends to influence the future development of European private law on the EU level. This sixth volume of the series presents "up-to-date" national reports of - The Netherlands - Switzerland - Czech Republic - Slovakia - Malta - Latvia

Download or read book Commentaries on European Contract Laws written by Nils Jansen and published by Oxford University Press. This book was released on 2018-07-12 with total page 2250 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides rule-by-rule commentaries on European contract law (general contract law, consumer contract law, the law of sale and related services), dealing with its modern manifestations as well as its historical and comparative foundations. After the collapse of the European Commission's plans to codify European contract law it is timely to reflect on what has been achieved over the past three to four decades, and for an assessment of the current situation. In particular, the production of a bewildering number of reference texts has contributed to a complex picture of European contract laws rather than a European contract law. The present book adopts a broad perspective and an integrative approach. All relevant reference texts (from the CISG to the Draft Common European Sales Law) are critically examined and compared with each other. As far as the acquis commun (ie the traditional private law as laid down in the national codifications) is concerned, the Principles of European Contract Law have been chosen as a point of departure. The rules contained in that document have, however, been complemented with some chapters, sections, and individual provisions drawn from other sources, primarily in order to account for the quickly growing acquis communautaire in the field of consumer contract law. In addition, the book ties the discussion concerning the reference texts back to the pertinent historical and comparative background; and it thus investigates whether, and to what extent, these texts can be taken to be genuinely European in nature, ie to constitute a manifestation of a common core of European contract law. Where this is not the case, the question is asked whether, and for what reasons, they should be seen as points of departure for the further development of European contract law.