Comparative law notes
Because the Willenserklärung is a central concept within the General Part of the German Civil Code and the General Part applies to and is superimposed on all the other parts (fields of law) of the German Civil Code, the concept itself must remain rather abstract and pliable. By contrast, under the common law, there is no such overarching abstract concept involving an expression of intent. Analogous concepts in individual fields of common law - e.g., intent to be bound under contract law and the creation of a last will and testament- also involve manifestations of intent, but these human expressions are analyzed separately under the applicable field of law. Thus, lawyers and legal translators have always relied on some neologism variation like statement of will or declaration of intent.