Abstract
In this text I present the German conflict–of–laws rule on voluntary agency, analysing the different connecting factors for the determination of the applicable law and the scope of the applicable law. Then I briefly compare the German conflict–of–laws rule to the regime under the Hague Convention on agency and under the Spanish civil code. © 2018 Iprolex. All rights reserved.
Translated title of the contribution | The German conflict rule on voluntary representation: Some comparative notes |
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Original language | Spanish |
Pages (from-to) | 373-397 |
Journal | Spanish Yearbook of Private International Law |
Issue number | 18 |
DOIs | |
Publication status | Published - 2019 |
Keywords
- Agency
- Hague convention on agency
- Introductory act to German civil code
- Private international law
- Spanish civil code