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提及财产,首先要联想到的是“物之所在地法”。运用这种原则地优点在于,它对法律适用提供了确定性,人们对不动产地所在地确信无疑,没有争论,不动产适用“物之所在地”法可能是一项全世界都遵从地法律原则。但是正是由于不动产不能流动,逐渐被现代贸易边缘化,更多地国际交往是建立在动产之上的。随着社会的继续发展,单一的“动产随人”原则已经不能满足动产转移的
When it comes to property, the first thing to think of is “the law of the place”. The advantage of using this principle is that it provides certainty about the application of the law, that there is no doubt that people are right where the real estate is located, that there is no dispute, and that the “place of residence” law may be a legal principle that the entire world follows. However, it is precisely because immovable property can not flow and is gradually being marginalized by modern trade, and more international exchanges are based on movable property. With the continuous development of society, the single principle of “movable property” can no longer satisfy the transfer of movable property