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