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