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Synopsis

For every transnational lawyer, it is vital to know the differences among national secured transactions law. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory chapters from comparative lawyers set the scene for this topic. The book presents a survey of the law relating to secured transactions in all member states of the European Union. Following the Common Core Approach the national reports are centered around 15 hypotheticals dealing with the most important issues of secured transactions law such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. Each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions.

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