Legal regulation of service and labor relations in various legal systems

Abstract

The article provides a comparative characteristic of the concepts of labor relations in some foreign countries. The article analyzes the legal regulation of labor relations, dividing states into two groups. The first includes Russia, France, Germany and a number of other European states. In the second - the USA, Great Britain, Australia and other countries of the Anglo-Saxon legal system. The author denotes the similarities and differences in choosing one of the two models, namely: European (continental) and Anglo-Saxon (Anglo-American). The conclusion is drawn that the borrowing of the experience of the countries adhering to the Anglo-Saxon model is unacceptable for the Russian state, since in them the labor contract is presented not as a tool capable of guaranteeing the rights of workers, but as a legal way to create conditions that can infringe on their interests. In turn, at the moment these countries are moving towards the socialization of labor relations.