Companies in the European Communities: Are the Conflict of Law Rules Ready for 1992?
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Authors
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.
Original language | English |
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Journal | Michigan Journal of International Law |
Volume | 11 |
Issue number | 4 |
Pages (from-to) | 1270-1293 |
Number of pages | 23 |
ISSN | 1052-2867 |
Publication status | Published - 1990 |
Externally published | Yes |
- Commercial law