Отново за обективно приложимото право към договорите
The Objectively Applicable Law to Contracts Revisited

Summary/Abstract: This article aims at revealing certain aspects of evolution in the conflict of law rules for determining the law applicable to contracts in the absence of choice materialized in five different sets of rules during the past fifteen years. The fact that the Rome Convention on the Applicable Law to Contractual Obligations is their prime source results in similar drafting, however, the existing divergences may lead to different ultimate solutions. This is specifically true when the conflict of law rules adopted by the national legislator have not been applied and interpreted in line with their prime source and with a view to the natural tendency of the court to apply its own law. The article consequently analyses and contrasts the relevant conflict of law rules under the repealed regulation of the Bulgarian Commerce Act and the Contracts and Obligations Act as well as the conflict of law rules under the Private International Law Code, the Rome Convention on the Applicable Law to Contractual Obligations and the Rome I Regulation, as these rules may apply according to the time of conclusion of the contract.

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