Article 25 – States with More than One Legal System

Research output: Chapter in Book/Report/Conference proceedingChapter


I. The notion of States comprising more than one legal system: 1. Composite, as opposed to unitary, legal systems; 2. The relevance of complex legal systems to the operation of the Rome II Regulation - II. The operation of the conflict-of-law provisions of the Regulation in the event of the designation of a complex legal system: 1. The problem with the designation of complex legal systems and the solution envisaged by the Regulation; 2. The rationale underlying the adopted solution; 3. Art. 25(1) as a guide to understanding references made to a State with more than one legal system for purposes other than the designation of the applicable law; 4. Issues, arising in respect of situations within the scope of application of the Regulation, to which Art. 25(1) does not apply - III. The non-application of the Regulation to purely local, as opposed to international, conflicts: 1. The solution adopted by the Regulation and its raison d’être; 2. The possibility for Member States to regulate local conflicts in conformity with the Rome II Regulation
Original languageEnglish
Title of host publicationRome II Regulation
EditorsU. Magnus, P. Mankowski
Number of pages10
Publication statusPublished - 2019


  • Diritto internazionale privato
  • Private international law
  • States with more than one legal system
  • Stati con più sistemi giuridici


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