Termination of civil obligations in a contractual manner (in the civil codes of Russia, France and Germany)

Repin Artem Vadimovich

The article is devoted to contractual methods of termination of civil obligations under Russian, German and French legislation. The author conducted a comparative legal analysis, identified the features of the application of the rules on compensation, novation, set-off, debt forgiveness, as well as the possibility of concluding an unnamed agreement in each of the countries and formulated conclusions about the distinctive and similar positions of legislators to contractual methods of termination of obligations.

Keywords:termination of obligations, novation, compensation, set-off, debt forgiveness, Russian law, German law, French law, contract.