The last four Argentine Draft Civil Codes unify both contractual and noncontractual liability systems. There is also a strong tendency among the Peruvian doctrine.
最后的四个阿根廷民法典草案都统一了契约与非契约责任制度。这种趋势也强烈地体现在秘鲁的学说中。
2
To complicate things even more, there is also the future Rome II Regulation on the law applicable to non-contractual obligations, (4) which is currently still in draft form.