Marietta Pietrek
Konsens über Tradition?
Eine Studie zur Eigentumsübertragung in Brasilien, Deutschland und Portugal
[Consensus over Tradition? A Study on the Transfer of Property in Brazil, Germany and Portugal.]
2015. XXIV, 337 pages. Summary
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Summary
The German and Portuguese legal systems are diametrically opposed regarding the transfer of both movable and immovable property. The Brazilian civil law strikes a balance between these two. However, this study shows that it should still not be the system of choice in a process of international harmonization.