التناسق بين القوانين الأكثر أمنا للأطراف ( دراسة مقارنة )

Abstract

That the facts on which the national legislator is based in determining the basic purpose of the attribution base that was dealt with in a previous and later era by most of the various legislations .And through general theoretical approaches that require acceptance or functional solution to the assignment role and this may not meet the legitimate expectations of individuals development taking place in different . Societies and the intertwining of international private relations with a foreign element and these legislations that do not meet the interests of individuals in the light of this development .And judge when the work of these rules is that rules of assignment are obligatory to take in to account the law and this not achieved in accordance with the Traditional approach only to .And through the functional role the rules of attribution and from the general principles of the natural function of the rule attribution is that it achieves consistency between and achieves material justice and in turn achieves legal security for the parties in the legal relationship in dispute it is necessary to stand at the purpose for which the rules of attribution were initiated, to search for solutions and to get out of the legislative stalemate to the find of flexibility in line with the development taking place in international private relations .