“Because of the system-bound nature of legal terms, full equivalence between terms from two legal systems is rare: translators most often deal with partial or zero equivalence / conceptual voids. Kjaer argues that ‘non-equivalence is the rule rather than the exception’ .. When searching for an equivalent, the translator should first decide whether it is possible to use a functional equivalent, also known as a dynamic or natural equivalent, that is a term which exists in the target legal system. This technique is regarded as the ideal solution …; however, Sarvcevic emphasises that its acceptability depends on the degree of incongruity between source language and target language concepts … functional equivalents are possible when incongruity is relatively small …”

Lucja Biel, Lost in the Eurofog: The textual fit of translated law, Peter Lang Editions (2014), p. 42