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Dimensions of coherence in EU conflict-of-law rules
Journal of Private International Law  (IF),  Pub Date : 2020-01-02, DOI: 10.1080/17441048.2020.1738624
Felix M. Wilke

EU conflict-of-law rules are contained mainly in six separate Regulations, with several others flanking them. This complex picture raises the questions of how easy access to this area of law is and to what extent it promotes legal certainty and predictability of results. Both issues link to the idea of coherence. Against this background, this article employs several different perspectives to examine the current level of coherence in EU conflict-of-laws rules analytically, also taking into account the recent Commission Proposal for a further Regulation. The article shows that, in particular, many structural and topical parallels exist, and argues that many remaining inconsistencies can easily (and should) be corrected because they are obvious and in part nearly inexplicable outliers.