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Cross-border Transfer and Collateralisation of Receivables - A Comparative Analysis of Multiple Legal Systems (Hardcover)
Loot Price: R3,632
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Cross-border Transfer and Collateralisation of Receivables - A Comparative Analysis of Multiple Legal Systems (Hardcover)
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Legal systems around the world vary widely in terms of how they
deal with the transfer of and security interests in receivables.
The aim of this book is to help international financiers and
lawyers in relevant markets in their practice of international
receivables financing. Substantively, this book analyses three
types of receivables financing transactions, ie outright transfer,
security transfer and security interests. This book covers
comprehensive comparison and analysis of the laws on the transfer
of and security interests in receivables of fifteen major
jurisdictions, encompassing common law jurisdictions,
Roman-Germanic jurisdictions and French-Napoleonic jurisdictions,
as well as relevant EU Directives. To be more specific, this book
compares and analyses the relevant legal systems of the US, Canada,
New Zealand, Australia, Korea, Japan, France, Belgium, England,
Hong Kong, Singapore, China, Germany, Austria and the Netherlands.
Furthermore, in order to analyse those legal systems from the
international perspective, this book compares relevant
international conventions; it also proposes to establish an
international registration system for the transfer of and security
interests in receivables.
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