A French judgment does not enforce itself outside France. It has to be admitted there. Everything depends on the country
Enforcing a French judgment abroad: EU, United Kingdom, Switzerland and non-EU countries Read Post »
Between EU Member States, exequatur has gone: since 10 January 2015 a French judgment that is enforceable in France is
An on-demand guarantee is paid without any discussion of the underlying contract: that is its whole purpose, and Article 2321
On-demand guarantees: how to defend against an abusive call Read Post »
Workshop led by Hervé Guyader on 24 September 2026 at the 34th ACE congress in La Grande-Motte: hardship in private international law, international trade law and maritime law.
ACE Congress 2026: hardship in international law Read Post »
Under French law, the shipyard remains owner of the yacht until acceptance, unless otherwise agreed. An advance payment made without
In the Netherlands, Germany and Italy, as in France, the shipyard owns the hull it builds unless otherwise agreed. What
Building a yacht in the Netherlands, Germany or Italy: the shipyard’s law compared Read Post »
Since 1 May 2026, a French ship mortgage can be granted on a ship under construction (Transport Code, article L.
Acceptance of the yacht after sea trials transfers ownership and starts the warranties running. Acceptance signed without reservation does not
Absent a clause, a yacht construction contract is governed by the law of the shipyard’s country (Rome I Regulation, article
Dispute with a foreign shipyard: governing law, competent court and arbitration Read Post »
Regulation (EU) 2026/2108 of 16 September 2026 was published in the Official Journal of the European Union on 19 September
The Union Customs Code: Regulation (EU) 2026/2108 has been published Read Post »
