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The author discusses whether institutional competition among member states in the European Union would be preferable to harmonization with respect to the future development of European private law, especially in the fields of corporate and contract law. The work was conceived partly as a result of the Centros decision of the European Court of Justice in 1999, in which the Court used the topos of "competition among legal systems" for the first time and enlisted its support for an extensive interpretation of the freedom of establishment.

Corporation law --- Contracts --- Restraint of trade --- Corporation law - European Union countries --- Contracts - European Union countries --- Restraint of trade - European Union countries