Arbitration analysis: On 28 February 2020, Dutch investment companies AES Solar Energy Coöperatief UA (AES) and Ampere Equity Fund BV (AEF) obtained €26.5m arbitral award against the Kingdom of Spain before the Permanent Court of Arbitration in Switzerland (the ‘Award’) currently pending enforcement before the District Court of Columbia in the US. In its strategy to avoid the enforcement, Spain requested a (sort-of) anti-suit injunction relief before the Dutch courts. To neutralise Spain's efforts, AES and AEF opposed the petition and assigned all their rights under the Award to a US entity Blasket Renewable Investments LLC (Blasket) to evade the jurisdictional reach of the Dutch courts. In its decision, the Amsterdam District Court Judge, Mr Justice HC Hoogeveen, in his judgment March 2023, considered the scope of its jurisdiction to decide on the relief sought by Spain under the Dutch Code of Civil Procedure (DCPR) and the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (NYC 1958). Under the DCPR, the Dutch Court considered that it does not have jurisdiction to hear the case as the potential damage arising from the award enforcement would not occur in the Netherlands but in the US, blaming Spain for having ‘wrongly created an additional forum’. Furthermore, the court remarks that there is no connection with the Dutch jurisdiction since the Award is against Spain because of an investment in this country, the arbitration took place in Switzerland, and its enforcement is taking place in the US. Similarly, under NYC 1958, the Amsterdam District Court confirmed that Switzerland ‘owns’ the exclusive jurisdiction for the annulment and enforcement of the arbitral award, as the country's supervisory courts where the Award was issued. Finally, the Dutch court also denied its jurisdiction to hear the case based on the place of enforcement as only the court of the country where the enforcement is taking place has jurisdiction, ie the US. As icing on the cake, the Dutch court also charged Spain with all the costs of the proceedings. Written by Josep Galvez, English barrister, Del Canto Chambers (London) and Spanish abogado, Litigo Partners (Barcelona).