Model EU and Pattern OHADA?

This volume contains all the papers presented during the working session of the Section for Comparative Commercial and Business Law at the 39th Conference of the German Society for Comparative Law in Berlin. Today, the European Union (EU) and the Organisation pour l'harmonisation en Afrique du droit des affaires (OHADA) are the two most integrated supra­national organisations in the world. On the one hand, OHADA was institutionally modelled on the EU. But on the other hand, based on an essentially French legal tradition, OHADA was able to go much further in the unification of commercial law, as evidenced by meanwhile eleven Uniform Acts relating to principally all aspects of commercial law. 140 years after the beginning of the so-called Berlin Conference concerning the Scramble for Africa this comparative approach also reflects the paradigm shift in the relationship between Europe and Africa.

Preface
Matthias Lehmann: From OHADA to the EU: How much uniform law is needed for a single market? - Paul Bayzelon: Conditions for legal harmonisation in the EU and OHADA - Gérard Ngoumtsa Anou: General commercial and commercial companies' law in the OHADA and EU - Seyoum Yohannes Tesfay: The impact of OHADA's Uniform Act relating to General Commercial Law in non-francophone Africa: The case of the Revised Commercial Code of Ethiopia - Nestor Kouami: The Stakes of Commercial Dispute Resolution in OHADA and EU Legal Frameworks - Jean Jacques Lecat: Practical Experiences on Implementing OHADA and EU Law