Cross-Border Services and Choice of Law. A Comparative Study of the European Approach

Par : Ulla Liukkunen
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  • Nombre de pages290
  • ISBN3-631-55964-X
  • EAN9783631559642
  • Date de parution01/12/2006
  • CollectionInternationalrechtliche Studie
  • ÉditeurPeter Lang

Résumé

This multidisciplinary study explores cross-border services from the viewpoint of private international law. It takes a fresh approach to this field of law and reflects on the multiple facets of the Europeanisation of conflicts rules in commercial law, consumer law, company law and labour law, confronted with the challenges of globalisation. The book examines, for instance, the interaction between different fields of law that has been enabled by the means of conflicts rules.
Also studied are the present challenges of the conversion of the Rome Convention into a Community instrument. The author focuses on a broad spectrum of problems caused by the fragmentation of conflicts law in Europe and seeks a way towards better coherence. With legal comparisons, an EU and US comparison included, the study seeks to provide a broader understanding of the characteristics of the Europeanisation of the conflict of laws.
The Author : The author of this book, Ulla Liukkunen, has specialised in private international law, comparative law, EU law and global law. For several years, she has been working as a senior adviser for legal affairs in demanding law-drafting tasks, including the transposition of EC legislation, both at national and EU level. The author is a senior researcher at the Institute of International Economic Law (KATTI) and responsible for the field of private international law at the University of Helsinki.
She is a docent in private international law and comparative law and an expert member of the Finnish Market Court.