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8.

The forms necessary for a juristic act are determined by the law by which its effect is determined.

Notwithstanding the foregoing provisions, the forms are sufficient, if they comply with the law of the country where the act was done; but this rule does not apply to juristic acts relating to the creation or disposal of real rights[1] or rights for which registration is required.

9.

As to an expression of intention made to a person who is in a place having a different law, the place from which the communication is sent is deemed to be the place of the act.

As to the existence or effect of a contract, the place from which the communication of the offer is sent is deemed to be the place of the act. If at the time when the person to whom an offer is made accepts it, the place from which the communication of the offer was sent is not known, the domicile of the offerer is deemed to be the place of the act.

10.

Rights in movables and immovables and rights for which registration is required, are governed by the law of the place where the things subject to such rights are situated.

The acquisition or loss of such rights is governed by the law of the place where the thing is situated when

  1. ↑ See Art. 175 et seq. of the Civil Code.
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