Statutenwechsel und Gerichtsstandswechsel

How does European private international law respond to changed circumstances? This work shows that changes of residence or domicile, contract amendments, or shifts in damages can alter the applicable law and jurisdiction of the Rome I, II, and Brussels Ibis Regulation—more often than previously assumed. Such shifts are referred to as “conflits mobiles”. They require changeable connecting elements in the conflict-of-law and jurisdiction rules. These issues have so far only been examined in a rudimentary and fragmented manner in the context of European Private International Law of contractual and non-contractual obligations, even though numerous constellations are possible and have already been addressed in case law.

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