Overview

International commerce is made more difficult and costly by the requirements of all the different legal systems involved - and nowhere more so than within the European Union. There are fundamental differences here between the attitudes and responses of the English common law and those of the civil law systems across the rest of Europe. The answers they give may be much the same in the end, but business people and legal practitioners clearly need to understand how very different the vocabularies and processes of argument and analysis can be. Earlier editions of this work proved very helpful for these purposes, and now another update has become necessary. The book explains in plain English the day-to-day realities of British business practices and usages as reflected in the decisions of the courts, and provides concise statements of equivalent rules in eight other EU jurisdictions - Denmark, France, Germany, Italy, The Netherlands, Poland, Spain, and Sweden - written by distinguished legal scholars from those countries. Scottish, Commonwealth and United States rules are also noted, as are the proposed Principles of European Contract Law. Appendices include essential United Kingdom statutory materials and the Vienna Convention on Contracts for the International Sale of Goods. This fifth edition of this important work, featuring some 150 new cases and new provisions in national codes, will be as widely welcomed by practitioners as by students of business and comparative law.

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