首页 >
法律 >
合同法 >
Place of Performance: A Comparative Analysis

Place of Performance: A Comparative Analysis

作者： Chukwuma Samuel Adesina Okoli
出版商： Hart Publishing
ISBN: 9781509943852
出版时间 November 2021
规格： Paperback
适应领域： U.K. ? 免责申明：
Countri(es) stated herein are used as reference only
Hardback Edition ISBN: 9781509936205

￥504.78

或

下载订单表

加入收藏
| 加入比较

描述
大纲

详细

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.
1. Introduction
I. Background
II. Scope of the Applicable Law: Place of Performance
III. Originality
IV. Methodology
V. Structure and Summary of the Book
VI. Some Observations on Terminology
2. Historical Analysis on the Place of Performance as a Choice of Law Rule
I. Introduction
II. Pre-Rome Convention
III. Rome Convention
IV. Rome I Regulation Proposal
V. Conclusion
3. Should the Place of Performance be Given Special Significance under a Revised Article 4 of Rome I Regulation?
I. Introduction
II. A Critical Analysis of the Rationale for the Doctrine of the Habitual Residence of the Characteristic Performer
III. Escape Clause and the Place of Performance
IV. Moving Towards the Place of Characteristic Performance: Some Issues
V. Conclusion
4. Article 9(3) of Rome I Regulation: Place of Performance as an Expression of the Principle of Proximity
I. Introduction
II. A Historical and Comparative Analysis: Pre-Rome Convention
III. Article 7(1) of the Rome Convention: Th e Principle of Proximity and the Place of Performance
IV. Article 8(3) of the Rome I Proposal: Th e Principle of Proximity and the Place of Performance
V. Article 9 of Rome I Regulation
VII. Conclusion
5. Coherence between Jurisdiction and Choice of Law: Implications for the Place of Performance
I. Introduction
II. Types of Coherence between Jurisdiction and Choice of Law
III. Historical Connection between the EU Jurisdiction and Choice of Law Regimes for Commercial Contracts:
A Critical Analysis
IV. Choice of Law as a Determinant of Jurisdiction under Article 7(1)(a) of Brussels Ia
V. What are the Differences between Choice of Law and Jurisdiction which Militate against Resolving them in the Same Manner?
VI. Why do European Jurisdiction Rules Support the Claim on the Significance of the Place of Performance of
the Commercial Contract in Choice of Law Matters?
VII. Conclusion
6. Legislative Proposal
I. Background
II. Proposed Model of a Revised Article 4 of Rome I Regulation and Accompanying Recitals
III. Alternative Proposal
7. Conclusion
I. Summary of the Research Findings
II. Transmission of the Model of the Revised Article 4 of Rome I Regulation to Other Countries or Legal Systems
III. Final Word

你可能需要


The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition): List Price: ￥502.90

￥487.81 Save ￥15.09 (3%)


Hong Kong Tax & Accounting Practical Toolkit (Basic Package): ￥3,420.66


Hong Kong Company Secretary Checklist, 2nd Edition: List Price: ￥1,297.20

￥1,258.28 Save ￥38.92 (3%)


Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book): List Price: ￥3,290.00

￥3,191.30 Save ￥98.70 (3%)


Butterworths Hong Kong Discrimination Law Handbook, 4th Edition: List Price: ￥1,410.00

￥1,367.70 Save ￥42.30 (3%)


Sentencing in Hong Kong, 11th Edition: List Price: ￥3,365.20

￥3,264.24 Save ￥100.96 (3%)


Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 6th Edition: List Price: ￥2,143.20

￥2,078.90 Save ￥64.30 (3%)


Butterworths Hong Kong Company Law Handbook, 26th Edition: List Price: ￥4,136.00

￥4,011.92 Save ￥124.08 (3%)


Cross-Border Crime in Hong Kong: Extradition, Mutual Assistance & Financial Sanctions, 3rd Edition: List Price: ￥1,955.20

￥1,896.54 Save ￥58.66 (3%)


Clough & Clough on Personal Injuries: List Price: ￥1,410.00

￥1,367.70 Save ￥42.30 (3%)


Hong Kong Personal Insolvency Manual, 3rd Edition: List Price: ￥1,880.00

￥1,823.60 Save ￥56.40 (3%)


Butterworths Hong Kong Conveyancing and Property Law Handbook, 6th Edition: List Price: ￥1,692.00

￥1,641.24 Save ￥50.76 (3%)


A Practical Guide to Resolving Shareholder Disputes, 2nd Edition: List Price: ￥1,692.00

￥1,641.24 Save ￥50.76 (3%)


Tort Law in Hong Kong, 5th Edition (Hardcopy + ebook): List Price: ￥2,350.00

￥2,279.50 Save ￥70.50 (3%)


Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book): List Price: ￥3,006.12

￥2,915.94 Save ￥90.18 (3%)


Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book): List Price: ￥2,672.42

￥2,592.25 Save ￥80.17 (3%)


Hong Kong Company Law, 15th Edition: List Price: ￥462.48

￥448.61 Save ￥13.87 (3%)


Private Equity in Hong Kong and China, 4th Edition: List Price: ￥1,880.00

￥1,823.60 Save ￥56.40 (3%)


Brooke's Notary Hong Kong, 3rd Edition: List Price: ￥1,598.00

￥1,550.06 Save ￥47.94 (3%)


Butterworths Hong Kong Employees' Compensation Handbook, 7th Edition: List Price: ￥1,974.00

￥1,914.78 Save ￥59.22 (3%)

“

Ordering from Professional Bookshop is fantastic, quick delivery great products, great customer service Siti L.
This is a great bookstore and have had no problems with them and all my orders have come on time and in good condition. Yang X.
Everything is perfect. Fast delivery. I highly recommend this website to all my friends and colleagues. Thanks Hoi Man L.
So thankful I am receiving all my books, thank you to all for a great service and excellent products Clinton K.
Professional Bookshop is amazing! I've been a loyal customer for over 5 years. Returns are easy to request, book or delivery complaints are taken seriously and the customer service team is friendly and patient. Mick D.
I wanted to informed you that the customer service is excellent. They were so polite and nice. I would continue to buy books from Professional Bookshop. Jingsong C.
Fast and quick service. Easy transaction method, arrived sooner than expected. Excellent packaging and the books received are in perfect condition! Thank you very much! I love the book and its quality. Saori B.
I can order any accounting books from worldwide from Professional Bookshop. Love this website and save my time to search from internet. Lingxiao R.
It is just so easy to find what you are always looking for and sometimes you can even find it up to 80% off what you would in the normal store. Graeme R.
I love shopping on Professional Bookshop! They have a wide range of accounting book with competent prices. Free shipping in Hong Kong is also really handy! Fergus Y.
Professional Bookshop is a great bookstore, I must say. Buying books in Professional Bookshop is so easy, great and reliable. It is highly recommendable. Deborah D.
A great site to shop accounting books and everything and with discountable prices. It’s my first choice whenever i want to shop something. Most trusted site. Zeng Z.
I found the books I needed and at a very low price. I am very happy and will definitely use it in the future Brian W.
I have been using Professional Bookshop for a while now. I am very impressed with customer service and delivery. When I need to have a return it is done very diligently. Olivia L.
Professional Bookshop is my default go to for finding the best prices and reading details of law books before buying. Detailed book description is very helpful. Tracy W.
I've been using Professional Bookshop since 2011 and they actually great, I always received great service and my book arrives on time. Lisa C.

所有书籍

Place of Performance: A Comparative Analysis

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

所有书籍

Place of Performance: A Comparative Analysis

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

video title