Giesen, Reinhard Die Anknüpfung des Personalstatuts im norwegischen und deutschen internationalen Privatrecht |
Reinhard GiesenDie Anknüpfung des Personalstatuts im norwegischen und deutschen internationalen Privatrecht[The Choice of Law in Matters Concerning Personal Status. An Analysis of Norwegian and German Private International Law.]Published in German. German private international law is characterized by an increasing withdrawal from the principle of nationality, and the international law of natural persons, family law and the law of succession are in a phase of development in Europe. The Norwegian experiences with linking this to the place of domicile, similar to the Anglo-Saxon principle of domicile, are noteworthy, and in view of the future developments in Europe, for which the principle of nationality is not suitable as a basis, they can be helpful. Reinhard Giesen describes the Norwegian system by drawing on rules and cases along with the typical Scandinavian legal realist approaches of Norwegian jurists and provides a unique insight into a legal system which in spite of its proximity is still quite foreign to German jurists. |
Law
Mohr Kurier
Books
by the author
in the series
Studien zum ausländischen und internationalen Privatrecht (StudIPR)