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The civil codes of the russian federation and the Netherlands: Similarities and contrasts

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Chapter Summary

The civil codes of Russian Federation and the Netherlands belong to the same family, but are not closely related. The work on the new Russian Code started too late for any influence on the Dutch Code. Similarly, the influence of the Dutch Code on the new Russian one, if any, has been slight. As shown in this chapter, the parallels are all more or less coincidental. The chapter compares the two codes in terms of their structure, scope, style, general standards, and interpretation. Some general observations are also made between the rules on both sides on legal persons and on the law of property and rights in rem, contract law and interpretation of contracts. The chapter also discusses certain practical problems such as secured transactions, the fiduciary transfer of property, the working of mandatory law, and the role of suppletive law.

Keywords: contract law; Dutch civil law; Law of Property; legal persons; mandatory law; Russian Civil Code; secured transactions; suppletive law

10.1163/ej.9789004155343.i-368.11
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