Die Anknüpfung von Vorfragen im europäischen Kollisionsrecht

The European Union is on its way to establishing a completely harmonized private international law. In January 2009, the Rome II Regulation took effect as the first of several regulations containing provisions concerning the special part of private international law. However, a uniform application of these provisions will only be assured if the member states of the EU also agree on how to solve problems of the general part of private international law. Carmen Christina Bernitt analyzes the highly disputed issue of preliminary questions and shows how the specifics of a European private international law influence the problem of preliminary questions. She proposes a uniform solution and verifies this by examining several preliminary questions which will arise with the application of the Rome II Regulation.