Property in comparative law

Property in comparative law is analyzed through the examples of French Austrian, German, Swiss, and Greek law. The selection of these legal systems as examples is based on the notion of property that each system has adopted. The French and Austrian Civil Law Codes adhere to the Roman subjective notion in defining property, which requires two elements: corpus-real power (control) over property and animus-will to retain property as one's own (ownership will). In contrast, the German and Swiss civil law codes define property objectively, as actual control over property. In defining property the Greek civil law code proceeds from the Roman concept, but in regard to succession and the protection of property, it adopts solutions from the German civil law code.