Dispute Resolution and Conflict of Laws

by Pfeiffer, Thomas; von Hein, Jan

• ISBN13: 9781509924158
• ISBN10: 1509924159
• Format: Hardcover
• Copyright: 2020-11-12
• Publisher: Nomos/Hart

Summary

As European conflict of laws principles, the Rome Regulations have largely replaced national regulations and are directly applicable in every EU Member State. Accompanied by the increasing number of cross-border issues in Europe, it is indispensable for national legal consultation to be acquainted with the relevant conflict of laws rules. The new European conflict of laws principles also have a major effect on classical core areas of civil law, including contractual law, criminal law and law of obligation. The new commentary analyses article-by-article all relevant European regulations:Rome I and Rome IIBrussels Ibis RegulationService RegulationTaking of Evidence RegulationEnforcement Order RegulationEuropean Insolvency RegulationIn addition, the commentary pays attention to on conventions of international arbitration: New York ConventionUNCITRAL-MLThe commentary focuses expressly on the recast of the Brussels I Regulation and the European Insolvency Regulation as well as on the relationship between the general conflict of laws rules and the national law of the Member States. It takes account of disputes before national courts such as arbitration proceedings.

Author Biography

Thomas Pfeiffer is Professor of Law at Heidelberg University and Director of the Institute for Private International Law, Comparative Law and International Business Law.Jan von Hein is Professor at the University of Freiburg, Germany and Director of the Institute for Comparative and Private International Law, Department III.