The European systems of real estate

Abstract

This paper shows an overview of the land registration systems in Europe. The comparative analysis starts from the distinction between the legal systems of the property transmission within the two large families of "Civil Law" and "Common Law". On these basis, in fact, the legal institutions and national organizations, that supervise the real estate registration, are built. Therefore the various systems of "Land Registration" were examined with reference to the main typical factors, such as the organization of the Register, the contents of the recording, its substantial effects, the protection of good faith and the effects to third parties.

Keywords

• Property rights
• Property registration
• Land Registers
• Grundbuch
• Civil Law
• Common Law
• Deed system
• Title system
• Mortgage Law
• Real rights
• Credit rights
• Land
• Land Registrar
• “Tavolare” system
• ELRA
• European Commission
• Civil Justice
• Legal protection