Succession Upon Death: A Comparison of European and Turkish Private International Law
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Beschreibung
Biset Sena Güneş addresses differences between the European Succession Regulation, the Turkish Private International Law Act of 2007 and the Turkish-German Succession Treaty of 1929. She offers a third state perspective on the European Succession Regulation and in particular indicates its interplay with the Turkish and the Treaty rules.
The European Succession Regulation, which harmonized private international and procedural law rules of Member States in the field of succession, has been examined by scholars in almost every detail. It has, however, not attracted the same degree of attention from a third state perspective. The aim of this book is to offer a comparative analysis of the Regulations's regime from a Turkish perspective. Turkey is indeed an important third state for cross-border succession cases for the EU, having a great number of nationals within the European Union and being one of the third countries which have bilateral treaties on succession with the Member States which are still applicable according to Article 75 of the Regulation. Biset Sena Güneş addresses the differences between the provisions of the Regulation, the Turkish PILA and the Turkish-German Treaty of 1929, the most practically relevant one of the treaties with third states, and indicates the interplay between the three legal texts.
Autor*in
Biset Sena Günes
Born 1987; legal studies at Istanbul University; LL.M. (Queen Mary University London); 2021 PhD (University of Regensburg); since 2020 Senior Research Fellow and Head of the Centre of Expertise on Turkey at the Max Planck Institute for Comparative and International Private Law, Hamburg.
Themen in »Succession Upon Death: A Comparison of European and Turkish Private International Law«
The European Succession Regulation Third States Turkey Jurisdiction Procedural Issues Conflict of Laws the European Certificate of Succession