The Conflict of Laws in Time and Space in International Private Law

摘要

An important role in solving a conflict is played by determining the time at which we are situated with respect to a legal relation that contains a foreign element: the time of emergence, change, transfer or termination of a legal relation; or the time of existence of that legal relation. When the conflict regards the emergence, change, transfer or termination of a legal relation, we are dealing with a conflict of laws in space, in the context of which it is necessary to establish the competent law to be applied, and when it regards a legal relation already acquired based on a foreign law, we are dealing with a conflict of laws in time and space, and in this case the effects that the acquired right produces on the territory of other states must be determined.