- No-deal Brexit and jurisdiction issues—the Swiss position
- Are you aware of any guidance published by the Swiss government, courts, bar or other authorities on the impact of a no-deal Brexit on civil justice matters involving UK parties? If so, please provide a copy or link.
- After exit day, what regime will the courts of Switzerland apply to jurisdiction clauses that give the English court jurisdiction? Is this different to the approach to jurisdiction clauses that give jurisdiction to courts in the US?
- After exit day, what regime will the courts of Switzerland apply to a jurisdictional dispute involving a party domiciled in the UK where proceedings were commenced?
- On or prior to exit day
- After exit day
- Does the answer to the above change if the defendant moves from Switzerland to the UK (or vice versa) after proceedings have commenced?
Dispute Resolution analysis: Dr Urs Feller, partner, Marcel Frey, counsel and Michaela Kappeler, associate, at Prager Dreifuss Ltd, Zurich, discuss from the Swiss perspective, the likely impact of a no-deal Brexit on civil justice matters involving UK parties and the approach to jurisdiction clauses, both prior to and after exit day.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial