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Cross-Border Services and Choice of Law

A Comparative Study of the European Approach

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Ulla Liukkunen

This multidisciplinary study explores cross-border services from the viewpoint of private international law. It takes a fresh approach to this field of law and reflects on the multiple facets of the Europeanisation of conflicts rules in commercial law, consumer law, company law and labour law, confronted with the challenges of globalisation. The book examines, for instance, the interaction between different fields of law that has been enabled by the means of conflicts rules. Also studied are the present challenges of the conversion of the Rome Convention into a Community instrument. The author focuses on a broad spectrum of problems caused by the fragmentation of conflicts law in Europe and seeks a way towards better coherence. With legal comparisons, an EU and US comparison included, the study seeks to provide a broader understanding of the characteristics of the Europeanisation of the conflict of laws.
Contents: Cross-border services – Private international law – Legal comparison – EU – EC law – Fragmentation of law – EU and US comparison – Commercial law – Consumer law – Labour law – Company law – Human and fundamental rights.