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Starting from the generally acknowledged fact that exact translation is not possible, this article presents the difficulties of translation between legal systems in general, which appear on different levels and are of such extent, that it has often been spoken about the untranslatability of law. The idea of untranslatability is a controversed one in the specialized literature, as some authors show that it is no case of absolute untranslatability, but one of relative untranslatability, since the translator – who has to bridge the gap between the source and the target legal system – must find a surrogate solution for the missing legal term.