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Reproduced with permission from Juridisk Tidskrift (1991/92) 1-28

excerpt from

Uniform Sales Law - The Experience with Uniform Sales Laws in the Federal Republic of Germany

Peter Schlechtriem [*]

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Because the delegates could not agree on the yardstick for the interest rate and whether it should be taken from the creditor's or the debtor's country, Art. 78 CISG states only the principle obligation to pay interest and is silent as the the details of the interest rate.[86] This means that private international law has to be referred to in order to determine the law governing the question of interest rate.

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Go to entire text of Schlechtriem commentary


* Dr. jur. ord. Professor Albert-Ludwigs-Universität Freiburg i. Breisgau, Director of the Institute of Foreign and Private International Law, Freiburg. President of the German Association of Comparative Law. The following article is based on a paper read to the Law Faculty of the University of Stockholm on Jan. 25, 1991. I have added footnotes and some remarks, but in general preserved the text of the oral lecture.

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86. See the discussion in O.R. 137-138, 173, 223-225, 388-392, 415-419, 429-430.

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Pace Law School Institute of International Commercial Law - Last updated August 16, 1999

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