Choice of Court Agreements after Brexit

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Authors	ZABLOUDILOVÁ Kateřina
Year of publication	2019
Type	Article in Proceedings
Conference	Universal, Regional, National – Ways of the Development of Private International Law in 21st Century
MU Faculty or unit	Faculty of Law
Citation
Web	Open access sborníku
Doi	http://dx.doi.org/10.5817/CZ.MUNI.P210-9497-2019
Keywords	Diversity of Substantive Law; Matrimonial Property Regimes; Matrimonial Property Regulation; Overriding Mandatory Provisions; Public Policy Exception; Regional Unification of the Conflict-of-law Rules
Description	The aim of the contribution is to assess whether Hague Convention on Choice of Court Agreement and Brussels Ibis Regulation are comparable legal instruments as far as choice of court agreements are concerned. The article shall analyze mutual features of the two legal instruments as well as their divergences in relation to choice of court agreements. The article shall demonstrate whether Hague Convention presents a complete and a comprehensive solution in terms of choice of court agreements for the UK provided that the Brussels Regulation is no longer applicable.
Related projects:	Universal, regional, national - ways of the development of private international law in 21th century