YEAR 2013 N.º 1
Agency; applicable law; international contract
Portuguese and Spanish PIL solve conflict of laws in matters of agency in different ways. Portugal’s accession to the Hague Convention of 1978 on the law applicable to agency, brought some coherence as conventional solutions are applicable to both internal and external relations on agency; on the contrary, in Spanish PIL there are different sources of conflict rules for these relations. Despite the differences there are issues and problems common to both jurisdictions caused by the complex nature of the agency and the dèpeçage adopted.