The aim of the article is to present the issue of territorial non‑uniformity of law in the context of private international law and internal regulations of countries whose legal systems are non‑uniform. Determining the applicable law within such countries may cause several difficulties, unable to be solved only by application of the private international law. Therefore in such situations it is necessary to apply its internal collision norms. The article presents the issue of territorial non‑uniformity
of law from two different perspectives. The first one consists on analyzing the matter of non‑uniformity of law from the point of view of both Polish and foreign regulations of private international law. The analysis in this regard is conducted on the basis of Polish Acts on Private International Law from 2011, 1965 and 1926 as well as the EU regulations. One of the most common ways of dealing with the problem of inter‑regional conflict of laws consists on that if within the country whose law is applicable there are in force several distinctive legal systems, then the law of this country shall specify which of these systems shall apply. Such solution was adopted also by the Polish Act of Private International Law from 2011. The second perspective presents the issue of territorial non‑uniformity of law from the point of view of Spanish inter‑regional regulations. These norms specify the applicable law within the framework of legal relations limited to Spain, however they can also apply for those legal relations which include a foreign element. In such case the norms of inter‑regional law complement the norms of private international law. The article presents the rules of Spanish inter‑regional law in the historical, systems and practical view. The analysis is conducted on the basis of Spanish legislation, jurisprudence and legal doctrine. Descriptive and comparative character of the article provides a comprehensive view of the issue of territorial non‑uniformity of law as well as possible ways of its regulation both in Polish and foreign private international law. It also helps to answer the question of how to specify the applicable law if the Spanish law shall apply.

This article is devoted to the issue of the statutory set‑off of competing claims in different currencies. At the outset, the author describes doctrine views on the legal definition of money from convertibility, which is a feature of those systems in which standard currency consists of gold, to the contemporary meaning of money. Finally, he assumes that — in the case of physical cash — the essential legal characteristic of money is the category of the unit of account. The second part of article discusses the question of homogeneity of claims expressed in different currencies. Two basic views are considered. According to one view claims expressed in different currencies generally cannot be set‑off, provided that no statutory exception can be applied, such as section 358 § 1 polish civil code stating: if money debt expressed in a foreign currency is payable within the country, payment may be made in the currency of such country, unless the payment in foreign money is expressly stipulated. The author advocates the contrary view. Thus requirement of homogeneity is fulfilled when both climes are expressed in freely convertible currencies. The earliest day when the mutual creditor is able to declare set‑off is decisive for applicable currency exchange rate.

In order to facilitate the cross‑border activities of foundations, and to make it easier for them to support public benefit causes across the EU, the European Commission has presented a proposal for a Statute for a European Foundation. This article describes the actual progress in the legislative process concerning the European Foundation (FE). The Proposal for a Council Regulation on the Statute for a European Foundation was presented by the European Commission on 8 February 2012, and was changed significantly by the European Parliament in its resolution of 2 July 2013.
After a concise presentation of the history of the legislative work on the project, the
article describes the following main features of the FE: its legal character, the necessary cross‑border dimension, public benefit purposes, founding assets and economic activities of an European Foundation, as well as the methods of establishing an FE and the registration requirements, the internal organisation of the FE and Member State supervision, registered office and its transfer, and, finally, the dissolution of the FE. The comparison between the rules included in the Proposal from 8 February 2012 and the changes brought by the European Parliament in its resolution of 2 July 2013 are supported by a presentation of current academic discussions concerning the creation of a European Foundation. The characteristics of a European Foundation, as set out in this article, reflect the possible shape of the new European legal form.

The issue of passing of risk remains one from the main aspects in international sales law. The buyer usually intends to receive the purchased item promptly; the seller on the other hand intends to deliver goods as soon as possible, because it determines how quickly he receives payment for goods sold and releases himself from other obligations towards seller. The parties may agree for any mean of transport, which can be done by any from the parties or by the third party. The main purpose of this article is an attempt to highlight interpretational differences between terms which were used by the framers of CISG and to explain that, under certain circumstances these differences may influence the transfer of risk and situation of both parties to the contract of sale.

This article contemplates the main principles of private international law of the United Arab Emirates issued by the Federal Law No. 5 of 1985 and subsequently amended by No.1 of 1987. The federal law is presented in the context of the legal system of the Emirates as a whole, including geopolitical and religious context. Although the basis of the legal system in the UAE are derived from Sharia Law (Islamic law) or Quranic Law, most of the legislation is comprised of a mix of Islamic and European concepts of civil law, largely originating from the Egyptian legal code established in the beginning of the 20th century. Civil law of the Emirates was generally influenced by the French legal system rather than the common law system of the UK. This article aims to introduce polish audience to the system of modern Arabic civil law, and presents a legal translation of the private international law of the United Arab Emirates.