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2006

Comparative and Foreign Law

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Comparative law

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La Propriété-Sûreté. Rapport Général, Mauro Bussani Jan 2006

La Propriété-Sûreté. Rapport Général, Mauro Bussani

Mauro Bussani

The aim of the paper is twofold. On the one hand, its goal is to offer a comparative overview of the rules and techniques on the use of ownership as security, with particular regard to retention of title and transfer of title for security purposes. On the other hand, the paper aims to illustrate the harmonization efforts which have been undertaken in this field, and to evaluate the promises and challenges arising from such integrative enterprises in light of the findings highlighted by comparative law studies.