Comparative contract law: England, France, Germany

Auteurs

• P. D. V. Marsh

Paramètres

• Sciences sociales

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We are, of course, all Europeans now. However, what strikes people who do business across the EU is the radical differences between legal systems and philosophies. It is dangerous to make assumptions about another country's law. Peter Marsh's book reviews and compares the main elements of English, French and German law as they relate to business contracts, especially contracts for the sale of goods and for construction work. He examines the formation of contracts, their validity, the obligations of the parties, the position of third parties, the control of unfair terms, and remedies for non-performance. By tracing current law back to its historical roots he also shows how both the similarities and the differences have developed and how one legal system could still learn from another.As the only single-volume treatment of French and German contract law in the English language, this book will be invaluable to British businesses trading with France and Germany, to lawyers who may be called upon to advise such businesses and to professionals in the construction industry who may be carrying out work in France or Germany.

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• Année de publication: 1993