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For every transnational lawyer, it is vital to know the differences
between national secured transactions laws. Since the applicable
law is determined by the place where the collateral is situated, it
may change when movables are brought from one state to another.
Introductory essays from comparative lawyers set the scene. The
book then presents a survey of the law relating to secured
transactions in the member states of the European Union. Following
the Common Core approach, the national reports are centred around
fifteen hypothetical cases dealing with the most important issues
of secured transactions law, such as the creation of security
rights in different business situations, the relationship between
debtor and secured creditor, the nature of the creditor's rights
and their enforcement as against third parties. each case is
followed by a comparative summary. A general report evaluates the
possibilities of European harmonisation in the field of secured
transactions law.
For every transnational lawyer, it is vital to know the differences
between national secured transactions laws. Since the applicable
law is determined by the place where the collateral is situated, it
may change when movables are brought from one state to another.
Introductory essays from comparative lawyers set the scene. The
book then presents a survey of the law relating to secured
transactions in the member states of the European Union. Following
the Common Core approach, the national reports are centred around
fifteen hypothetical cases dealing with the most important issues
of secured transactions law, such as the creation of security
rights in different business situations, the relationship between
debtor and secured creditor, the nature of the creditor's rights
and their enforcement as against third parties. each case is
followed by a comparative summary. A general report evaluates the
possibilities of European harmonisation in the field of secured
transactions law.
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