Comparative analysis of the legal regulation of the real estate lease abroad (by the example of the Czech Republic, Croatia, Poland)

The present work is focused on a comparative analysis of the legal regulation of the real estate lease abroad. The specifics of the legislative regulation of the contract of the real estate rental contract on the example of the Czech Republic, Croatia and Poland are defined. The features of legislative regulation of the object, form, subject matter, leasehold of the real estate in the above-mentioned foreign countries are considered. As a result of the study the authors conclude that there are three approaches of foreign legislators to the legal regulation of the real estate lease: regulation by means of the Civil Code; regulation by means of a special legal act; mixed legal regulation. The results of the study can be used as part of the study of international legal acts and as a comparison of foreign normative acts with Russian ones.