In force in 70 countries around the world and covering more than two thirds of world trade, the 1980 United Nations Convention on Contracts for the International Sale of Goods (CISG) is considered to be the most successful convention promoting international trade. According to many commentators, this success is due, among others, to the fact that the Convention does not directly impact on the domestic law of the various legal systems, as it applies only to international - as opposed to purely domestic - contracts. The Convention, in other words, does not impose changes in the domestic law, which makes it easier for States to adopt the Convention. This does not mean, however, that the Convention does not have any impact on the domestic law at all. This book analyzes - through 24 country reports as well as a general report submitted to the 1st Intermediate Congress of the International Academy of Comparative Law held in November 2008 in Mexico City - to what extent the Convention de facto influences domestic legal systems. In particular, the book examines the Convention's impact on the practice of law, the style of court decisions as well as the domestic legislation in the area of contract law.
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Weitere Infos & Material
1;Frontmatter;1
2;Table of contents;5
3;Preface;9
4;Argentina;13
5;Brazil;17
6;Canada;43
7;China;81
8;Croatia;103
9;Czech Republic;117
10;Denmark;123
11;France;139
12;Germany;153
13;Greece;173
14;Israel;193
15;Italy;197
16;Japan;235
17;Mexico;241
18;New Zealand;261
19;Russia;269
20;Slovenia;275
21;Spain;283
22;Switzerland;291
23;United Kingdom;313
24;United States of America;323
25;Uruguay;343
26;Venezuela;347
27;The CISG’s Impact on EU Legislation;355
28;The CISG and its Impact on National Legal Systems – General Report;423
29;Questionnaire;491
30;Backmatter;495
