This book provides an unprecedented analysis on the place of
performance. The central theme is that the place of performance is
of considerable significance as a connecting factor in
international commercial contracts. This book challenges and
questions the approach of the European legislator for not
explicitly giving special significance to the place of performance
in determining the applicable law in the absence of choice for
commercial contracts. It also contains, inter alia, an analogy to
matters of foreign country mandatory rules, and the coherence
between jurisdiction and choice of law. It concludes by proposing a
revised Article 4 of Rome I Regulation, which could be used as an
international solution by legislators, judges, arbitrators and
other stakeholders who wish to reform their choice of law rules.
General
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