The registration of advance notice is a very important system about transference of estate right, which can take precautions against risk. Many countries and regions of the civil law systems adopt this system. And our country will also set it up in the future as we expected. From the present situation, we just have knowledge on the system, thus lots of problem in profound level have not been involved and some limitations in details also have been neglected. If the registration system of advance notice is established on the basis of this knowledge, its value will be reduced. For this reason, when it compares with the registration system of advance notice in Germany, Japan and the area of Taiwan, it will get the overall and breakthrough knowledge. This thesis totally includes four parts.The first chapter studies the comparative law on the scope of applying registration of advance notice. In Germany, the registration of advance notice is applied to the right of appeal on the change of the right of estate, as well as Taiwan. The former appeal right is also applied to the future appeal right and the appeal right subject to conditions. But the former right of appeal, which is defined to the appeal right subject to conditions and time limit for registration of advance notice, is a future right. In Germany, registration of advance notice is not only applied to the appeal right subject to conditions and time limit, but also the future appeal which has broad legal basis and is used to according to the purpose of obligee. This opening regulation with strong adaptability is also one of the character is tics of the relevant regulations in Japan. The above... |