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International Property Law Comparison
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United States
Characterized by a strong protection of ownership rights.
Germany
Known for its detailed land register system.
China
Land is state-owned or collectivity-owned; private land ownership is not possible.
Australia
Utilizes a Torrens title system for land registration.
Brazil
Rights to property are well protected, but bureaucracy can be an obstacle.
France
Notaire system ensures legal safety in transactions.
India
Property law is a mix of modern legislation and customary law.
Japan
Has a reliable and efficient property registration system.
Canada
Provincial governments have primary responsibility for property law.
South Africa
Based on Roman-Dutch law; also influenced by common law.
United Kingdom
Leasehold and freehold estates are the main forms of property interest.
Russia
Transitioned from Soviet-era laws to a new property law regime.
Italy
A notary public plays a central role in property transfers.
Spain
Civil law system with a cadastre and land registry.
Mexico
Land reform laws historically important; modern laws promote market efficiency.
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