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Fourth completed book of the Common Core of European Private Law launched at the University of Trento.
For every transnational lawyer, it is vital to know the differences among national secured transactions law. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory chapters from comparative lawyers set the scene for this topic. The book presents a survey of the law relating to secured transactions in all member states of the European Union. Following the Common Core Approach the national reports are centred around 15 hypotheticals dealing with the most important issues of secured transactions law such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. Each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions.
Table of content:
General editors' preface; Preface; List of contributors; Table of cases cited by name; Table of legislation; Part I. Introduction and Context: List of abbreviations; 1. Introduction: security rights in movable property within the common market and the approach of the study Eva-Maria Kieninger; 2. A labyrinth of creditors: a short introduction to the history of security interests in goods Willem J. Zwalve; 3. Security in movables in the United States - uniform commercial code article 9: a basis for comparison Harry C. Sigman; 4. The English law of security: creditor-friendly but unreformed Michael Bridge; 5. The European bank for reconstruction and development's secured transactions project: a model law and ten core principles for a modern secured transactions law in countries of central and eastern Europe (and elsewhere!) Frédérique Dahan and John Simpson; Part II. The Case Studies: List of abbreviations; Bibliographies; Glossary; Case 1: furniture for a new office; Case 2: the deceived seller; Case 3: machinery supplied to be used by the buyer; Case 4: jackets for resale; Case 5: motor cars supplied and resold (I); Case 6: motor cars supplied and resold (II); Case 7: supply of material to manufacturer (I); Case 8: supply of material to manufacturer (II); Case 9: too many toasters; Case 10: bank loan on the basis of a car fleet; Case 11: bank loan for a wholesaler; Case 12: bank loan on the basis of money claims (I); Case 13: bank loan on the basis of money claims (II); Case 14: finance leasing of computers; Case 15: indebted businessman sells business to brother; Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisation Eva-Maria Kieninger; Index by country; Index by subject.
Hinweis: Dieser Artikel kann nur an eine deutsche Lieferadresse ausgeliefert werden.
For every transnational lawyer, it is vital to know the differences among national secured transactions law. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory chapters from comparative lawyers set the scene for this topic. The book presents a survey of the law relating to secured transactions in all member states of the European Union. Following the Common Core Approach the national reports are centred around 15 hypotheticals dealing with the most important issues of secured transactions law such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. Each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions.
Table of content:
General editors' preface; Preface; List of contributors; Table of cases cited by name; Table of legislation; Part I. Introduction and Context: List of abbreviations; 1. Introduction: security rights in movable property within the common market and the approach of the study Eva-Maria Kieninger; 2. A labyrinth of creditors: a short introduction to the history of security interests in goods Willem J. Zwalve; 3. Security in movables in the United States - uniform commercial code article 9: a basis for comparison Harry C. Sigman; 4. The English law of security: creditor-friendly but unreformed Michael Bridge; 5. The European bank for reconstruction and development's secured transactions project: a model law and ten core principles for a modern secured transactions law in countries of central and eastern Europe (and elsewhere!) Frédérique Dahan and John Simpson; Part II. The Case Studies: List of abbreviations; Bibliographies; Glossary; Case 1: furniture for a new office; Case 2: the deceived seller; Case 3: machinery supplied to be used by the buyer; Case 4: jackets for resale; Case 5: motor cars supplied and resold (I); Case 6: motor cars supplied and resold (II); Case 7: supply of material to manufacturer (I); Case 8: supply of material to manufacturer (II); Case 9: too many toasters; Case 10: bank loan on the basis of a car fleet; Case 11: bank loan for a wholesaler; Case 12: bank loan on the basis of money claims (I); Case 13: bank loan on the basis of money claims (II); Case 14: finance leasing of computers; Case 15: indebted businessman sells business to brother; Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisation Eva-Maria Kieninger; Index by country; Index by subject.
Hinweis: Dieser Artikel kann nur an eine deutsche Lieferadresse ausgeliefert werden.