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International Construction Law: An Overview


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CHAPTER 9

South America

Alexandre Aroeira Salles, Federico Allendes, Francisco Ferreira, and Mariana Miraglia

History of South American Legal Systems

Introduction


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9.1 South America is made up of a diverse range of countries with distinct historical and cultural backgrounds. The manner in which the legal systems across South America developed is heavily influenced by colonization from the Portuguese and Spanish. Brazil is the largest country in South America in terms of size and economy and is the only major South American country to have been colonized by the Portuguese.1 The other major South American countries were largely colonized by the Spanish and of these countries Chile is recognized as having a particularly sophisticated legal system which has heavily influenced a number of other key legal systems across South America. The Chilean Civil Code, which has its roots in the private law of Castile, Spain, was either fully adopted or heavily influenced the development of the civil codes in a number of South American countries including Argentina, Colombia and Uruguay.

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