Das niederländische Übereignungssystem als mögliches Vorbild für Europa

While many areas of private law have been largely harmonized by European law, property law, and in particular the transfer of ownership, is still regulated very differently in the various EU member states. This work examines the structural principles underlying the transfer of ownership. It focuses on Dutch property law, which forms a middle ground between the extremes existing in the EU. In addition, it is disputed in the Netherlands whether a real agreement exists. In comparison with German law, it is examined whether the real agreement offers added value outside of the principle of abstraction and which system is the more consistent overall.