States, Industrial Policies & Antidumping Enforcements in Japan, South Korea and Taiwan
3 Buff. J. Int'l L. 289 (1997)
125 Pages Posted: 4 Nov 2019
Date Written: 1997
Abstract
The limited aim of this article is to review salient features of CISG, highlighting areas where CISG differs from or is more detailed than the legal norms set forth in the Korean Civil and Commercial Codes, the primary sources of Korean law governing commercial sales. France and other European and Latin American countries with civil tradition legal systems similar to Korea's contributed greatly to the multilateral negotiations which created the CISG text, accordingly many parts of the CISG will appear immediately familiar to Korean jurists. At the same time, because CISG was drafted after deliberation on the unique characteristics of international sales of goods and required accommodation of legal principles derived from dissimilar legal systems, there are a number of significant divergences from existing Korean law." Comparative reference will also be made to the UCC of the United States, to the laws of other civil law countries, and to court and arbitral decisions interpreting CISG where such reference helps clarify the approach of CISG or Korean law to particular issues.
Keywords: East Asian Studies, Japan, South Korea, Taiwan, Convention on the Contract for the International Sale of Goods
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