Cross-Border Security over Tangibles / / Harry C. Sigman, Eva-Maria Kieninger.
As cross-border trade and cross-border financing continue to increase while security rights over tangible property are governed by the law of the place where the moveable is situated, comparative knowledge of national secured transactions law is crucial for everyone using security rights over tangib...
Saved in:
Superior document: | Title is part of eBook package: De Gruyter DGBA Backlist Complete English Language 2000-2014 PART1 |
---|---|
VerfasserIn: | |
MitwirkendeR: | |
Place / Publishing House: | Munich : : Otto Schmidt/De Gruyter european law pub, , [2009] ©2007 |
Year of Publication: | 2009 |
Language: | English |
Series: | Schriften zum Gemeinschaftsprivatrecht ,
|
Online Access: | |
Physical Description: | 1 online resource (256 p.) |
Tags: |
Add Tag
No Tags, Be the first to tag this record!
|
Other title: | Frontmatter -- Table of Contents -- Abbreviations -- Introduction -- The Case Studies -- Germany -- France -- England and Wales -- Italy -- Netherlands -- Belgium -- Spain |
---|---|
Summary: | As cross-border trade and cross-border financing continue to increase while security rights over tangible property are governed by the law of the place where the moveable is situated, comparative knowledge of national secured transactions law is crucial for everyone using security rights over tangibles in a cross-border context. This book provides an in-depth examination of the key issues that arise when security rights are created, perfected and enforced in different European countries. Authored by experts on German, English, Dutch, French, Belgian, Italian and Spanish law, the national reports use practical cases and highlight differences and similarities. A special focus is placed on the way in which national courts deal with security interests created elsewhere. A comprehensive introductory chapter analyzes significant secured transactions issues, summarises the comparative data and compares them with Art. 9 of the Uniform Commercial Code (U.S.) and suggests guiding principles for a European harmonization measure or national reform efforts. The book will assist market participants and their counsel to better understand secured transactions law and relevant private international law rules of their own and other countries and assist those involved in national, EU and global law reform efforts. |
Format: | Mode of access: Internet via World Wide Web. |
ISBN: | 9783866537057 9783110238570 9783110621006 9783110636208 9783110219517 9783110219524 9783899496871 |
ISSN: | 2194-3664 |
DOI: | 10.1515/9783866537057 |
Access: | restricted access |
Hierarchical level: | Monograph |
Statement of Responsibility: | Harry C. Sigman, Eva-Maria Kieninger. |