PROPERTY LAW IN THE CONFLICT OF LAWS: EUROPEAN AND EAST ASIAN REGULATORY MODELS

Larisa I. Volova, Anastasia D. Suzdaleva

Abstract


The economic development of some East Asian states generates interest for the key features of East Asian national legislation when applying their experience in the law-making activities of the other states. One of these key features can be represented by a special model of cross-border property relations regulation concerning movables that tend to have a considerable influence on transnational business interaction. The aim of the article is to look over the patterns of European and Asian regulatory models of cross-border movable property relations and to compare their ability to induce cross-border economic cooperation. This article examines the opportunity to adopt the successful experience of legal regulation in this sphere and also highlights some of the differences that may inhibit business interaction between entrepreneurs from European and East Asian countries.

Keywords


Property Law, Movable Property, Conflict of Laws, Party Autonomy, Closest Connection Principle, European countries, East Asian countries.

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DOI: http://dx.doi.org/10.13165/j.icj.2017.12.005

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