Das internationale Privatrecht von Ecuador

Daniel Kadner analyzes the private international law of Ecuador, whose corresponding provisions are contained mainly in Ecuador's Civil and Commercial Codes. Ecuador adopted both of these Codes from the Chilean Law Codes, as did several other South American countries. The author begins by describing the history of private international law in Ecuador and by investigating the general principles of the conflict of law rules. The Ecuadorian private international law is governed by the principle of territorialism, which was shaped in the past century by the author of the Chilean Civil Code, Andres Bello. Daniel Kadner scrutinizes the often rather incomplete conflict of law rules for the different areas of private law, taking Chilean law into consideration and also dealing with the relevant conventions regarding conflicts of law ratified by Ecuador.