This book provides an unprecedented analysis on the place of performance. The central theme is that the place of performance is of considerable significance as a connecting factor in international commercial contracts. This book challenges and questions the approach of the European legislator for not explicitly giving special significance to the place of performance in determining the applicable law in the absence of choice for commercial contracts. It also contains, inter alia, an analogy to matters of foreign country mandatory rules, and the coherence between jurisdiction and choice of law. It concludes by proposing a revised Article 4 of Rome I Regulation, which could be used as an international solution by legislators, judges, arbitrators and other stakeholders who wish to reform their choice of law rules.
- ISBN10 1509943854
- ISBN13 9781509943852
- Publish Date 25 November 2021
- Publish Status Forthcoming
- Publish Country GB
- Publisher Bloomsbury Publishing PLC
- Imprint Hart Publishing
- Format Paperback (US Trade)
- Pages 312
- Language English