Cross-Border Security over Tangibles / Harry C. Sigman, Eva-Maria Kieninger.

Format:

Book

Author/Creator:

Sigman, Harry C., author.

Kieninger, Eva-Maria, author.

Series:

Schriften zum Gemeinschaftsprivatrecht

Language:

English

Subjects (All):

Security (Law)--European Union countries--Congresses.

Security (Law).

Conflict of laws--Security--European Union countries--Congresses.

Conflict of laws.

Physical Description:

1 online resource (279 p.)

Place of Publication:

Munich : sellier european law publishers, [2009]

Language Note:

English

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.

Contents:

Frontmatter

Table of Contents

Abbreviations

Introduction

The Case Studies

Germany

France

England and Wales

Italy

Netherlands

Belgium

Spain

Notes:

Description based upon print version of record.

Includes bibliographical references.

Description based on online resource; title from PDF title page (publisher's Web site, viewed 08. Jul 2019)

ISBN:

9786612274725

1-282-27472-4

3-86653-705-0

OCLC:

434591856