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Implementing the Cape Town Convention and the Domestic Laws on Secured Transactions

Implementing the Cape Town Convention and the Domestic Laws on Secured Transactions

  • 作者:
  • 出版商: Springer-Verlag
  • ISBN: 9783319464688
  • 出版时间 February 2017
  • 规格: Hardback
  • 适应领域: Switzerland ? 免责申明:
    Countri(es) stated herein are used as reference only
AU$328.32
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  • 描述 
  • 大纲 
  • 详细

    This book offers the analysis of the relationship between the Cape Town Convention and national laws on secured transactions. The first part of the book considers why national implementation is so important in the case of the Cape Town Convention and identifies how innovative the Convention is as a uniform law instrument. The second part includes chapters on those states that are Parties to the Cape Town Convention, which analyse how the Convention is implemented under the domestic law. The third part includes chapters on those states that are not Parties to the Convention, which compare their national laws and the Convention to find unique features of the Cape Town Convention's rules. The fourth part discusses the meaning of Protocols on aircraft, railway rolling stock and space assets from the practitioner's point of view. As a whole, the book offers insights into the new stage of uniform private law and shows the need for further examination of the subject, which will be essential for international and national legislators, academics of comparative and international private law as well as practitioners who are the users of the uniform law regime.

  • Foreword
    Roy Goode
    About the Authors

    Part I Introduction,- About This Book
    Souichirou Kozuka
    Implementation of the Cape Town Convention into and its relationship with National Law
    Jeffrey Wool

    Part II General Report
    2. The Cape Town Convention and its implementation in domestic law: General report
    Souichirou Kozuka

    Part III National Reports
    A. Parties to the Cape Town Convention
    3. Les suretes sur des aeronefs en droit canadien, la Convention relative aux garanties internationales portant sur des materiels d'equipement mobiles et son Protocole aeronautique
    Frederique Sabourin
    4. The law of England and Wales on secured transactions as compared with the Cape Town Convention
    George Leloudas
    5. Indonesia's Report: The Implementation of The Cape Town Convention 2001
    Prita Amalia
    6. Implementation of the Cape Town Convention in Malaysia
    Mary George and Vince See
    7. The Cape Town Convention on International Interests in Mobile Equipment and its implementation in the Netherlands and on the Dutch Caribbean Islands
    Sjef van Erp
    8. Russian legislation and Cape Town Convention
    Nataliya Doronina
    9. The Cape Town Convention and its Implementation in South African Air Law
    Phetole Sekhula
    10. The Cape Town Convention and its Implementation in Spanish Law
    Teresa Rodriguez de las Heras Ballell
    11. United States of America: Reconsidering the Transaction Document Filing Requirement for National Registry
    Charles W. Mooney, Jr.
    B. Non State Parties to the Cape Town Convention
    12. Finnish Mortgage System for Means of Transport: Outdated and Overly Complex?
    Teemu Juutilainen
    13. La Convention du Cap et sa reconnaissance en droit francais
    Philippe Delebecque
    14. Security interests in mobile equipment under German law - Some notes on the similarities and differences in relation to the Cape Town regime
    Benjamin von Bodungen
    15. The Greek Law on Security interests burdening transport vehicles as compared with the Cape Town Convention
    Elina N. Moustaira
    16. The Cape Town Convention and Italian Law on Secured Transactions
    Anna Veneziano
    17. The Security interest in transport vehicles in Japan
    Haruna Fujisawa
    18. The Cape Town Convention and Polish law on security interests
    Maria Dragun-Gertner, Zuzanna Peplowska-Dabrowska and Jacek Krzeminski
    19. Security interests in transport vehicles: The Cape Town Convention and Portuguese law
    Maria Helena Brito
    20. Rapport suisse sur le theme " Les suretes grevant les moyens de transport - La Convention du Cap et sa transposition en droit national "
    Benedict Foex

    Part IV Comments from the Practice
    21. Analysing the Effects of the Cape Town Convention on Four Selected Issues That Hinder the International Financing and Leasing of Aircraft and Engines
    Patrick Honnebier
    22. The Luxembourg rail protocol to the Cape Town convention: Some Practical Differences from the Aviation Protocol
    Howard Rosen
    23. Entering into force: Promoting Unidroit's Space Protocol among emerging space actors
    Daniel A. Porras
    Appendix: Questionnaire for national reporters.

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