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The Operation of the Escape Clauses in the Rome Convention, Rome I Regulation and Rome II Regulation [PDF]
(2012). The Operation of the Escape Clauses in the Rome Convention, Rome I Regulation and Rome II Regulation. Journal of Private International Law: Vol. 8, No. 3, pp. 513-545.
OKOLI, Chukwuma +1 more
exaly +3 more sources
Consumer protection under the Brussels I bis and Rome I Regulations
The trend towards globalization and the completion of the European Union's internal market has also led to an increase in the incidence of relations with a foreign element in international trade.
Dominika Moravcová
doaj +1 more source
Applicable Law on Contractual Obligations in European Union and American Law [PDF]
In EU and American law, the principle of autonomy has been recognized. For the purpose of unification, Rome 1 Regulation allows parties to choose the law that has no link to the contract. By contrast, in American law, the selected law is required to have
Homayoun Mafi, Mohammad Hosien Taghipoor
doaj +1 more source
The present article focuses on the scope of the key sources of judicial cooperation in civil and commercial matters within the EU, namely the Brussels I bis, Rome I and Rome II Regulations, in the context of the activities of public authorities.
Dominika Moravcová
doaj +1 more source
This article examines the rules for determining an objectively applicable law, namely habitual place of work and the engaging place of business and escape clause according to Rome I Regulation.
Justinas Usonis, Augustina Martinėlytė
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Overriding mandatory rules and public policy [PDF]
Overriding mandatory rules represent norms that are directly applied to the legal relationship with the foreign element. These are self-limiting norms, which exclude the application of collision rules, and they, in advance, define the field of their own ...
Čolović Vladimir Ž.
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OVERRIDING MANDATORY PROVISIONS IN CROATIAN PRIVATE INTERNATIONAL LAW
Overriding mandatory provisions are mandatory provisions that are applicable in situations with an international element. The author analyses overriding mandatory norms in the European private international law and in the Croatian national private ...
Dora Zgrabljić Rotar
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The Effect of the Rome I Regulation upon parties Choice of Non – state Law and " Amiable Composition " in Arbitration [PDF]
The study aims to explore the effect of the Rome I Regulation upon parties' choice of non-state law or resolving the dispute ‘amiablecomposition’ in arbitration.
Dr. Ala’eldin Mohammad ABABNEH Mohammad ABABNEH
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The article explores Article 14 on choice of law by the parties in Rome II and the possibilities for party autonomy. There is a limit to party autonomy where both parties are not ‘pursuing commercial activities’, which is meant to protect weaker parties.
Michael Hellner
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Both the 1980 Rome Convention and the Rome I Regulation on the law applicable to contractual obligations have not addressed the issue of the proprietary effects of assignments. Intense doctrinal debate, discussion of the issue in various appellate courts’
Herbert Kronke
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