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@inbook{884850,
author = {Rozehnalová, Naděžda and Valdhans, Jiří},
address = {New York},
booktitle = {Second Decade Ahead: Tracing the Global Crisis},
edition = {1},
keywords = {Rome I Regulation - Rome II Regulation - conflit of laws - choice of law clause - foreign element - mandatory rules - overriding mandatory rules},
language = {eng},
location = {New York},
isbn = {978-1-57823-272-7},
pages = {3-24},
publisher = {Juris Publishing},
title = {A Few Observations on Choice of Law},
year = {2010}
}
TY - CHAP
ID - 884850
AU - Rozehnalová, Naděžda - Valdhans, Jiří
PY - 2010
TI - A Few Observations on Choice of Law
VL - Czech Yearbook of International Law
PB - Juris Publishing
CY - New York
SN - 9781578232727
KW - Rome I Regulation - Rome II Regulation - conflit of laws - choice of law clause - foreign element - mandatory rules - overriding mandatory rules
N2 - Th is paper from the area of PIL addresses certain aspects of the choice of law under the universal collision rules of Community law for Rome I Regulation and Rome II Regulation. The authors discuss the institution of choice of law from the vantage point of Czech PIL, and in doing so reflect the differences brought about by the fact that the Rome I came into being by way of a transformation of an international convention. Since these two rules of community law contain no longer any choice-of-law concept in its pure form, but various forms of limitations, the authors engage in an analysis of these individual types. Their rejection of the generally accepted doctrine according to which choice of law is permissible in intrastate obligations appears controversial. Situations that were possible at the time at which the Rome Convention was still in force are no longer permissible under the Rome I and Rome II Regulations. Other limitations of the choice of law have also found the interest of the authors.
ER -
ROZEHNALOVÁ, Naděžda a Jiří VALDHANS. A Few Observations on Choice of Law. In \textit{Second Decade Ahead: Tracing the Global Crisis}. 1. vyd. New York: Juris Publishing. s.~3-24, 21 s. Czech Yearbook of International Law. ISBN~978-1-57823-272-7. 2010.
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