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The Italian Law Journal
This work aims to provide a contribution to the standardization of European law in the field of transfer of ownership. At first sight, the European scenario appears to present a very marked contrast between the French model of transfer of property based on the contract (titulus), and the German one, which is based on delivery (modus). Nevertheless, deeper analysis reveals that the differences are not as great as they seem. For instance, let us consider the Italian case, where, in spite of thefatcat:63t6p3qqyjc6lmn4jsjahtcjb4