Overview

As cross-border trade and cross-border financing continue to increase, and 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, summarizes the comparative data and compares them with Article 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 will assist those involved in national, EU, and global law reform efforts.

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9783866530379

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