The essay deals with the interpretation compliant with the EU directives according to the comparative method, thus showing that it is necessary to interpret the term to be compared according to the hermeneutical method used in a given system. As regards the national court's obligation to interpret the national law in the light of Community law, the reference is to the Italian model and the German one. In Italy, what prevails is an approach based on the theory of the sources of law, while in Germany is the methodological approach. The contribution recognizes the similarities and differences emerged in the subject of the interpretation compliant with the Basic Law and in that of the interpretation compliant with the EU directives. Finally, the contribution proposes to integrate the principle of the interpretation compliant with the EU directives in the hermeneutical activity of the domestic jurist.
File in questo prodotto:
Non ci sono file associati a questo prodotto.