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物之所在地法原则是物权法律适用的基本原则,但在涉外动产物权领域单一适用物之所在地法忽视了物权和债权关系的内在联系。《涉外民事关系法律适用法》将意思自治原则引入动产物权法律适用具有法理依据,符合冲突正义的要求,但意思自治原则只是物之所在地法的补充,应当对相关条文进行严格的限制性解释。
The principle of the location of the objects is the basic principle of the application of the law of real property. However, the law of the location of the sole applicable object in the field of real property rights of the foreign affairs ignores the intrinsic connection between the property rights and the claims. The Law on the Application of Law Concerning Civil Relations Concerning Foreign Affairs has the principle of legal basis for introducing the principle of the autonomy of will into jurisprudential basis and meets the requirements of conflict justice. However, the principle of autonomy of will only supplements the law of the place where the property is located and should strictly restrict the relevant provisions .