Acceso usuarios
1. Le varie tecniche a disposizione del legislatore nazionale. - 2. La soluzione adottata dai legislatori di Repubblica ceca - 3. Segue: Spagna - 4. Segue: Austria - 5. Segue: Olanda - 6. Segue: Germania - 7. Segue: e Belgio. - 8. Prospettive di riforma della legge n. 218/1995.
The proliferation of European Regulations on private international law and judicial cooperation challenges national legislators with the problem of integrating such Regulations into the national system, of making it clear to operators that they prevail over domestic rules, and, where needed, of assessing the interface between such regulations and existing international conventions. Three approaches bave been variously admixed by national legislators that have addressed that problem thus far: the provision of a general reservation of the Regulations in force, the formall recall of the individual Regulations in the various matters, and the transposition of the content of Regulations into national law. The present contribution provides a brief comparative analysis of the integration techniques used in six countries (Czech Republic, Spain, Austria, The Netherlands, Germany, and Belgium) and of the solutions adopted therein to regulate the cases excluded from the scope of the Regulations. The ultimate goal is to draw some indications for the much-needed reform of the Italian Law n. 218 of 1995 reforming the private international law system.
