Implications of Article 81(1) TFEU's recognition clause for EU conflict of laws rules University of Antwerp
The last decades have been marked by the extensive Europeanisation of conflict of laws rules. Traditionally, national conflict of laws rules in Continental Europe were aimed at determining the closest connection between the legal relation and the putatively applicable law. This universal objective was often combined with more local objectives: the achievement of certain substantive policies of the forum through conflictual mechanisms. The ...