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A Comparison between the Mexico City Convention and the Rome Convention
Jönköping University, Jönköping International Business School.
2005 (English)Independent thesis Advanced level (degree of Magister), 20 points / 30 hpStudent thesis
Abstract [en]

This thesis is a comparison between the Mexico City Convention and the Rome Convention concerning the Conventions’ scope of application, how the applicable law to a contract is determined, and how the applicable law is affected by mandatory rules and public policy. The two Conventions deal with the question of which country’s law is to apply to a contract with international connections.

The Conventions do in several situations lead to the same outcome as far as the applicable law is concerned. The reason for this is partly that the Mexico City Convention is based on the Rome Convention. However, there are also differences. One difference between the Conventions is the structure used. The wording of the Rome Convention is more detailed than the wording used in the Mexico City Convention. Another difference that exists concerns the characteristic performance test which is not used in the Mexico City Convention. Moreover, the Mexico City Convention is the more recent one of them, something that is notable in certain provisions since another and more modern approach is chosen. A more notable adjustment to the needs of the international trade is chosen.

Place, publisher, year, edition, pages
2005. , p. 64
Keywords [en]
Private International Law, Choice of Law
National Category
Law (excluding Law and Society)
Identifiers
URN: urn:nbn:se:hj:diva-259OAI: oai:DiVA.org:hj-259DiVA, id: diva2:3961
Uppsok
samhälle/juridik
Supervisors
Examiners
Available from: 2005-09-15 Created: 2005-09-15

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CiteExportLink to record
Permanent link

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Citation style
  • apa
  • harvard1
  • ieee
  • modern-language-association-8th-edition
  • vancouver
  • Other style
More styles
Language
  • de-DE
  • en-GB
  • en-US
  • fi-FI
  • nn-NO
  • nn-NB
  • sv-SE
  • Other locale
More languages
Output format
  • html
  • text
  • asciidoc
  • rtf