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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2022: Abstracts

Conflict of Laws

the ECJ obliged Bulgaria to recognise the Spanish birth certificate of a child in which two female EU citizens, married to each other, were named as the child’s parents, as far as the implementation of the free movement of persons under EU law was concerned, but left the determination of the family law effects of the certificate to Bulgarian law.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 5/2022: Abstracts

Conflict of Laws

Prior to the Rome Regulations, the conflict-of-law judgments on those “contracts with protective effect in favour of third parties” differed between German and Austrian courts. It points out that the Regulation Rome I covers only obligations that would not exist without the contract.