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Edited by Jürgen Basedow, Giesela Rühl, Franco Ferrari and Pedro de Miguel Asensio

The role and character of Private International Law has changed tremendously over the past decades. With the steady increase of global and regional inter-connectedness the practical significance of the discipline has grown. Equally, so has the number of legislative activities on the national, international and, most importantly, the European level. With a world-class editor team, 500 content items and authorship from almost 200 of the world’s foremost scholars, the Encyclopedia of Private International Law is the definitive reference work in the field. 57 different countries are represented by authors who shed light on the current state of Private International Law around the globe, providing unique insights into the discipline and how it is affected by globalization and increased regional integration. The Encyclopedia consists of three inter-linked pillars, enhanced by sophisticated search and cross-linking functionality. The first pillar consists of A-Z coverage of the scope and substance of Private International Law in the form of 247 entries. The second pillar comprises detailed overviews of the Private International Law regimes of 80 countries. The third pillar presents valuable, and often unique, English language translations of the national codifications and Private International Law provisions of those countries. This invaluable combination represents a powerful research tool and an indispensable reference resource.
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Edited by Jürgen Basedow, Giesela Rühl, Franco Ferrari and Pedro de Miguel Asensio

own national legal system of private international law including international and European instruments applicable in their country. In contrast, a global and comparative perspective is very often lacking. The Encyclopedia which the editors hereby present to the public sets out to improve the availability of information about private international law and to present the field from a global and comparative perspective. It is meant to provide a survey of the current state of legislation and case law in as many countries as possible, to introduce the reader to the

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Edited by Jürgen Basedow, Giesela Rühl, Franco Ferrari and Pedro de Miguel Asensio

Part I: National Statutes And Provisions Albania Law No. 10 428 of 2 June 2011 on Private International Law Angola Civil Code Code of Civil Procedure Argentina Commercial and Civil Code of 7 October 2014 Australia Foreign Judgments Act 1991 Austria Federal Statute of 15 June 1978 on Private International Law Belarus Civil Code of the Republic of Belarus Belgium Law of 16 July 2004 Holding the Code of Private International Law Bosnia and Herzegovina Act Concerning the Resolution of Conflicts of

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Edited by Jan M. Smits

The first of its kind, this comprehensive Encyclopedia on comparative law takes stock of present-day comparative law scholarship. Written by authorities in their respective fields, the contributions in this accessible book cover and combine not only questions regarding the methodology of comparative law, but also specific areas of law (such as administrative law and criminal law) and specific topics (such as accident compensation and consideration). In addition, the Encyclopedia contains reports on a selected set of countries legal systems and as a whole presents an overview of the current state of affairs.
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Arnald J. Kanning

economic activity. It follows that, to understand private law harmonization, an investigation of whether separate jurisdictions, constrained by economic rivalry, will succeed in providing private law that facilitates economic activity as much as possible does not suffice. The latter issue * See also: Comparative law and economics; Private international law. 208 Coordination of legal systems B’s Strategy y y A’s Strategy z 0, 0 2, 1 1, 2 z 0, 0 209 Figure 19.1 Coordination of legal systems (a) has received considerable scholarly attention (see, e.g., La Porta et al

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Horatia Muir Watt

to be the shared province of private international law and comparative legal studies, which are both recognised as having important implications for global governance. Three Encounters This contribution will envisage more specifically three ways in which comparative law can shed light on private international law. * See also: Agency and representation; Arbitration; Comparative law and economics; Trust law. 701 SMITS ENCY V2 9781849804158 PRINT .indd 701 30/08/2012 12:08 702 ● ● ● Elgar encyclopedia of comparative law, second edition The first is the most

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Edited by Thomas Cottier, Krista Nadakavukaren Schefer, Jonas Baumann, Brigitta Imeli, Julian Powell and Rebecca Gilgen

Creating this Encyclopedia of International Economic Law was an experiment in conceptualizing an extremely broad set of rules, principles, norms, and practices carried out by a remarkably extensive set of diverse actors and applying to a very wide and diverse set of human activities. International economic law, long virtually ignored by the general public international law community, has finally emerged from being considered a narrow set of technical rules of importance only to international traders to being recognized as a key component of international law

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Edited by Thomas Cottier and Krista Nadakavukaren Schefer

Creating this Encyclopedia of International Economic Law was an experiment in conceptualizing an extremely broad set of rules, principles, norms, and practices carried out by a remarkably extensive set of diverse actors and applying to a very wide and diverse set of human activities. International economic law, long virtually ignored by the general public international law community, has finally emerged from being considered a narrow set of technical rules of importance only to international traders to being recognized as a key component of international law

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Edited by Thomas Cottier and Krista Nadakavukaren Schefer

Creating this Encyclopedia of International Economic Law was an experiment in conceptualizing an extremely broad set of rules, principles, norms, and practices carried out by a remarkably extensive set of diverse actors and applying to a very wide and diverse set of human activities. International economic law, long virtually ignored by the general public international law community, has finally emerged from being considered a narrow set of technical rules of importance only to international traders to being recognized as a key component of international law

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Heinz-Peter Mansel

Council of Private International Law. Only after the so-called ‘ Spanier ’-decision of the German Federal Constitutional Court it was conceded that the constitution had a direct impact on choice-of-law rules (Gerhard Kegel, ‘Chapter 1: Introduction’ in Konrad Zweigert and Ulrich Drobnig (eds), International Encyclopedia of Comparative Law III/1 (Mohr Siebeck 1986) paras 1–12). In order to ensure the functionality of the national choice-of-law rules, he also rejected direct encroachments of the primary European law on the lex lata choice-of-law rules of the Member