Zderzenie kultur prawnych w Europejskim prawie kolizyjnym w kontekście swobody przedsiębiorczości
Clash of Legal Cultures in the European Conflict Law in the Context of the Freedom of Establishment

Summary/Abstract: The increasing economic activity and the integration of markets in the European Unionallow more and more companies for cross-border economic activity and cross-bordertransformation. However, in order to enable companies to restructure successfully acrossborders and to choose law that best fits their organizational structures and economic needs, the barriers resulting from different traditions and doctrines of law must be removedas they severely limit the possibility to make quick and effective decisions, reallocateresources or restructure. The existing differences between the national systems ofconflict law and regulations concerning the freedom of establishment cause that the effectsof cross-border activities are not always transparent and predictable. For this reason,Europe should clearly and explicitly define the relationship between the national rules oncompany law and the choice of appropriate law which will allow companies for greatermobility both in Europe and outside.

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