چکیده:
Occasionally, the conflict of laws becomes more complicated with factor intervention. In fact, the situation created and eliminated at the moment are very rare, and often they continue to develop over a certain period of time. It is clear that expanding these situations in time makes them sensitive to changes in laws. The effect that these changes can have on the law applicable to the legal relationship creates the problem of conflict at the time. But what further complicates this problem is that time-domain interference has many kinds to take into consideration that recognizing this issue will result in the identification of suitable solution for each of the conflicts of time. In this article, a variety of these states and their solutions will be investigated and it wiil be shown that time factor interference does not lead to the same results.
خلاصه ماشینی:
In private international law, the issue of time is often raised in the three forms mentioned, namely transitional rights of conflict-of-laws rules ٤, the issue of changes in the designated foreign law, and dynamic conflict.
According to this theory, given the numerous similarities between conflicts of laws in place and time, the goal of both sciences is to find the most appropriate law to manage a legal situation; a similarity that, based on this transfer of solutions between the issue of moving conflict and the sequence of domestic substantive laws, is based on the fact that in both cases, two laws are applicable one after the other, and one must be chosen between them) :1959,Level 78-72(.
Currently, the dominant doctrine in French law recommends transferring the solutions of domestic transitional law in order to resolve the issue of moving conflict )162 :2014 , ́Mayer et Heuze( which is consistent with Article 2 of the French Civil Code) :2014 ,Garaud 77(.
Mayer and Heuze, while criticizing the theory of similarity, explain the solution of transitional law and moving conflict, stating that the task of the conflict of laws rule is to determine the applicable law to the legal issue.
In this way, it becomes clear: In Iranian private international law, to solve the moving conflict regarding movable property, the same criterion regarding domestic transitional rights, namely the rule of immediate effect of the law in time, must be followed.
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