Die Haftung des gesetzlichen Abschlussprüfers im Internationalen Privatrecht

The question which law is applicable on the liability of the statutory auditor has a high practical relevance due to the different liability regimes in many countries and frequent cross-border situations. Taking into account the partial standardisation of private international law within Europe (Rome I- and Rome II-Regulation), a uniform European application of these provisions is required. This issue has not yet been subject to a comprehensive scientific analysis.
The work analyses the characterization and the relevant connecting factors of the auditor’s liability towards the audited company and third parties. The deficiencies of the current conflict of laws provisions are presented in detail and practical solutions are proposed.