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Place of Performance
Chukwuma Okoli
其他書名
A Comparative Analysis
出版Bloomsbury Publishing, 2020-05-28
主題Law / InternationalLaw / Conflict of Laws
ISBN150993622X9781509936229
URLhttp://books.google.com.hk/books?id=ex_cDwAAQBAJ&hl=&source=gbs_api
EBookSAMPLE
註釋This book provides an unprecedented analysis on the place of performance. The central theme is that the place of performance is of considerable significance as a connecting factor in international commercial contracts. This book challenges and questions the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains, inter alia, an analogy to matters of foreign country mandatory rules, and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation, which could be used as an international solution by legislators, judges, arbitrators and other stakeholders who wish to reform their choice of law rules.