Turkish and EU Private International Law A Comparison

This book grew out of a workshop that took place at the Centre for Private International Law at the Law School of the University of Aberdeen on 1 February 2013 as a part of a European Union (EU) funded project within the scope of the Lifelong Learning Programme of the EU Commission (Jean Monnet Scheme) analysing cross border litigation in Europe. The book consists of seven chapters which are the revised and edited versions of the papers that were given at the workshop on Turkish perspectives on EU Private International Law in preparation for Turkish accession to the EU and implications for the accession. This book gives an introduction to Turkey's EU accession process and reflects Turkish perspectives on jurisdiction, recognition and enforcement of judgments and applicable law in civil and commercial matters, private international aspects of family law, succession, intellectual property, competition law and unfair competition matters by making comparisons between Turkish Law and EU Law to see the influence of the latter on the former. The chapters address the significant differences between Turkish Private International Law and harmonised EU Private International Law which highlights the adjustments that Turkey will need to make when it accedes to the EU. CONTENTS CHAPTER 1: Turkey's EU Accession Process: Current State of Play in Accession Negotiations Sanem Baykal CHAPTER 2: Jurisdiction, Recognition and Enforcement of Judgments under Turkish Law in Comparison with the Brussels I Regulation Bülent Çiçekli CHAPTER 3: Jurisdiction, Applicable Law, Recognition and Enforcement of Foreign Judgments in Turkish Family Law Ziya Akıncı CHAPTER 4: Comparison of Articles 20 and 43 of the Turkish Private International Law and Procedural Law Act ('PILA') with the EU Succession Regulation Nuray Ekşi CHAPTER 5: Choice of Law in Civil and Commercial Matters under Turkish Private International Law in Comparison with Their Equivalents under the Rome I and Rome II Regulations Burcu Yüksel CHAPTER 6: Intellectual Property Rights in Turkish Private International Law and a Comparative Analysis on Applicable Law to Contractual Obligations B. Bahadır Erdem CHAPTER 7: Private International Law Aspects of Competition Law and Unfair Competition Matters under Turkish Law Bilgin Tiryakioğlu