TY - JOUR

T1 - Companies in the European Communities

T2 - Are the Conflict of Law Rules Ready for 1992?

AU - Reindl, Andreas

PY - 1990

Y1 - 1990

N2 - This article describes the current situation in the emerging integrated system of the European Community, focusing on the potential conflict between Community rules on the freedom of establishment and national conflict-of-law rules relating to companies. In the first part, I shall outline the relevant provisions of EC law and the two conflict-of-law concepts presently exhibited in the national laws of the Member States. In the second part, I shall discuss three cases in which the European Court of Justice recently addressed this subject. In the third part, I shall analyze the impact of the Court's opinions, and finally outline options for future legislative and other action.

AB - This article describes the current situation in the emerging integrated system of the European Community, focusing on the potential conflict between Community rules on the freedom of establishment and national conflict-of-law rules relating to companies. In the first part, I shall outline the relevant provisions of EC law and the two conflict-of-law concepts presently exhibited in the national laws of the Member States. In the second part, I shall discuss three cases in which the European Court of Justice recently addressed this subject. In the third part, I shall analyze the impact of the Court's opinions, and finally outline options for future legislative and other action.

KW - Commercial law

M3 - Journal articles

VL - 11

SP - 1270

EP - 1293

JO - Michigan Journal of International Law

JF - Michigan Journal of International Law

SN - 1052-2867

IS - 4

ER -