オーストリアにおける所有権留保 : 目的物の共有構成の可能性

Regarding the retention of ownership, Austrian law is strongly influenced by German law, just as in Japanese law. Although Austrian law does not provide for the retention of ownership in civil and insolvency laws, it is permitted by the principle of freedom of contract. This point is similar in Japanese law. However, unlike Japanese law, Austrian law treats objects as co-ownership in some cases. This suggests the necessity of studying the legal structure of Japanese law.