要旨.pdf

The chapter discusses the unification of global rules for promoting international transactions, but notes that countries often do not participate in global rule unification due to historical, cultural, or economic reasons, resulting in local rules that differ from country to country. However, international private law has adopted the principle of applying the law of the country most closely related to the international transaction, which increases the possibility of applying the same rules to the same transaction regardless of the country where the trial is held. This approach respects the local values of other countries involved in the transaction. While international law has created a framework for free international transactions, international private law maintains the function of preserving local values that are difficult to unify. Additionally, countries are increasingly harmonizing their legislation with global rules and other countries' legislation, and global rules are also incorporating advanced domestic legislation.