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A hard Brexit for European cross-border dispute resolution? - What companies outside the EU and the UK should know (Part II)

In our previous newsletter “A hard Brexit for European cross-border dispute resolution? – What companies outside the EU and the UK should know (Part I)”, we provided an introduction into two key issues parties involved in a cross-border dispute should be aware of after the United Kingdom’s (“UK”) withdrawal from the European Union (“EU”) (so-called “Brexit”): jurisdiction and service of process. In this Part II, we provide insight into questions surrounding the governing law, choice of law, taking of evidence and recognition and enforcement of judgments. In doing so, we revisit the hypothetical case we already discussed/presented in Part I: A Japanese company operates in Europe through a subsidiary with its office in Duesseldorf, Germany (“JP Corp.”). In January 2021, JP...To read the full article, please see the PDF file

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Authors

ラース・マーケルト

Lars’ practice is focused on commercial and investment arbitration. He has particular expertise in contentious proceedings involving post-M&A, commercial, manufacturing, construction, and distribution matters, in areas such as life sciences, automotive, and energy. Lars also deals with cases involving governments, and has advised foreign investors and sovereign states on issues of foreign direct investment and public international law, including related negotiations and investor-state disputes. He has been involved in more than 50 international arbitrations as counsel and arbitrator under the arbitration rules of institutions such as the ICC, DIS, SAC, NAI, ICDR, KCAB, JCAA, SIAC, and ICSID, as well as under the UNCITRAL Rules.