The Vienna Sales Convention (1980) follows in large measure the American Uniform Commercial Code: Article 2 on Sales. Is this to imply that the Contracting States to the Vienna Sales Convention really prefer American sales law? This paper answers this question in the negative, and argues instead...

In order to be able to assess the future institutional relationship between the UK and the EU, this study organises the relevant facts systematically. This is done by using a framework in which two aspects are compared with each other: On the one hand, the extent of the Single Market access for...

The principle of the mutual recognition of national regulations is often seen as the best course towards the realization of the EC single market, but there still remains great uncertainty concerning the interpretation of this principle. Which companies must observe which regulations? Will there...

The optimal scope of legal harmonization and the desirable patterns of lawmaking vary according to current legal, social and economic conditions. In this paper we specify a positive and testable hypothesis according to which legal systems respond to exogenous changes in the external environment...