Full Description
This book is devoted to the applicable law to contractual and non-contractual obligations in the European Union. The Rome I and II Regulations provide uniform conflict-of-laws rules in order to avoid undue forum-shopping. In theory, all national courts of EU Member States (excluding Denmark) apply the same rules determining the applicable law. Rome I and Rome II in Practice examines whether the theory has been put into practice and assesses the difficulties that may have arisen in the interpretation and application of these Regulations. Such a study appears invaluable as the Rome I and II Regulations may be seen as a critical stepping stone towards the construction of a true and far-reaching European Private International Law. Providing clear and detailed insights into the national case law of most EU Member States, as well as the case law of the Court of Justice of the European Union, and followed by a comparative analysis, this book is a valuable resource for practitioners, the judiciary and academics who are interested in understanding how EU law is applied on national and European levels.
Contents
Introduction (p. 1) Questionnaire for the National Reports (p. 5) Court of Justice of the European Union (p. 11) Austria and Germany (p. 41) Belgium (p. 89) Bulgaria (p. 103) Croatia (p. 131) Cyprus (p. 153) Czech Republic (p. 171) France (p. 191) Greece (p. 223) Hungary (p. 249) Ireland (p. 267) Italy (p. 293) Latvia (p. 349) Lithuania (p. 387) Luxembourg (p. 399) The Netherlands (p. 417) Poland (p. 445) Portugal (p. 465) Slovakia (p. 485) Slovenia (p. 527) Spain (p. 551) United Kingdom (p. 579) Conclusion (p. 625)
