European University Institute Library

International reservation of title clauses, a study of Dutch, French, and German private international law in the light of European law, Jacobien W. Rutgers

eng

Includes bibliographical references (pages 217-228) and index

index present

non fiction

International reservation of title clauses

bibliography

43259196

Jacobien W. Rutgers

Published EUI PhD theses

a study of Dutch, French, and German private international law in the light of European law

The rules of substantive law relating to the reservation of title clause differ from country to country. This book addresses problems which may arise if a reservation of title clause is employed within international transactions, especially transactions between Germany, France, and the Netherlands. The author seeks the solution in private international law, since other means of addressing the problem, such as harmonization and unification of substantive law rules, have failed so far. This study makes an important contribution to the understanding of European integration in a hitherto relatively neglected area.--Provided by publisher

Preface List of abbreviations Introduction 1. Substantive law 1.1 Dutch substantive law 1.2 German substantive law 1.3 French substantive law 1.4 Conclusions 2. Private international law and international jurisdiction 2.1 Introduction 2.2 International jurisdiction rules 2.3 Dutch private international law 2.4 German private international law 2.5 French private international law 2.6 Conclusions 3. The influence of European law on the conflict rules governing a reservation of title clause 3.1 Introduction 3.2 Private international law and the four freedoms 3.3 The applicable provision of the EC treaty 3.4.1 The scope of Article 30 3.5 Exceptions to the free movement of goods 3.6 Mutual recognition 3.7 Conclusions 4. Conclusions Table of cases Bibliography Index