-
1.
Treaties
Is your country party to any bilateral or multilateral treaties for the reciprocal recognition and enforcement of foreign judgments? What is the country’s approach to entering into these treaties, and what, if any, amendments or reservations has your country made to such treaties?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
2.
Intra-state variations
Is there uniformity in the law on the enforcement of foreign judgments among different jurisdictions within the country?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
3.
Sources of law
What are the sources of law regarding the enforcement of foreign judgments?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
4.
Hague Convention requirements
To the extent the enforcing country is a signatory of the Hague Convention on Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters, will the court require strict compliance with its provisions before recognising a foreign judgment?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
5.
Limitation periods
What is the limitation period for enforcement of a foreign judgment? When does it commence to run? In what circumstances would the enforcing court consider the statute of limitations of the foreign jurisdiction?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
6.
Types of enforceable order
Which remedies ordered by a foreign court are enforceable in your jurisdiction?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
7.
Competent courts
Must cases seeking enforcement of foreign judgments be brought in a particular court?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
8.
Separation of recognition and enforcement
To what extent is the process for obtaining judicial recognition of a foreign judgment separate from the process for enforcement?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
9.
Defences
Can a defendant raise merits-based defences to liability or to the scope of the award entered in the foreign jurisdiction, or is the defendant limited to more narrow grounds for challenging a foreign judgment?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
10.
Injunctive relief
May a party obtain injunctive relief to prevent foreign judgment enforcement proceedings in your jurisdiction?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
11.
Basic requirements for recognition
What are the basic mandatory requirements for recognition of a foreign judgment?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
12.
Other factors
May other non-mandatory factors for recognition of a foreign judgment be considered and, if so, what factors?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
13.
Procedural equivalence
Is there a requirement that the judicial proceedings where the judgment was entered correspond to due process in your jurisdiction and, if so, how is that requirement evaluated?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
14.
Personal jurisdiction
Will the enforcing court examine whether the court where the judgment was entered had personal jurisdiction over the defendant and, if so, how is that requirement met?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
15.
Subject-matter jurisdiction
Will the enforcing court examine whether the court where the judgment was entered had subject-matter jurisdiction over the controversy and, if so, how is that requirement met?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
16.
Service
Must the defendant have been technically or formally served with notice of the original action in the foreign jurisdiction, or is actual notice sufficient? How much notice is usually considered sufficient?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
17.
Fairness of foreign jurisdiction
Will the court consider the relative inconvenience of the foreign jurisdiction to the defendant as a basis for declining to enforce a foreign judgment?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
18.
Vitiation by fraud
Will the court examine the foreign judgment for allegations of fraud upon the defendant or the court?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
19.
Public policy
Will the court examine the foreign judgment for consistency with the enforcing jurisdiction’s public policy and substantive laws?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
20.
Conflicting decisions
What will the court do if the foreign judgment sought to be enforced is in conflict with another final and conclusive judgment involving the same parties or parties in privity?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
21.
Enforcement against third parties
Will a court apply the principles of agency or alter ego to enforce a judgment against a party other than the named judgment debtor?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
22.
Alternative dispute resolution
What will the court do if the parties had an enforceable agreement to use alternative dispute resolution, and the defendant argues that this requirement was not followed by the party seeking to enforce?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
23.
Favourably treated jurisdictions
Are judgments from some foreign jurisdictions given greater deference than judgments from others? If so, why?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
24.
Alteration of awards
Will a court ever recognise only part of a judgment, or alter or limit the damage award?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
25.
Currency, interest, costs
In recognising a foreign judgment, does the court convert the damage award to local currency and take into account such factors as interest and court costs and exchange controls? If interest claims are allowed, which law governs the rate of interest?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
26.
Security
Is there a right to appeal from a judgment recognising or enforcing a foreign judgment? If so, what procedures, if any, are available to ensure the judgment will be enforceable against the defendant if and when it is affirmed?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
27.
Enforcement process
Once a foreign judgment is recognised, what is the process for enforcing it in your jurisdiction?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
28.
Pitfalls
What are the most common pitfalls in seeking recognition or enforcement of a foreign judgment in your jurisdiction?To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us. -
Updates and trends
To read more
sign up for access
or
login here.
In house counsel join for free. Individual practitioners and lawyers may register for a free trial. For information on firmwide subscriptions please contact us.
or take a tour
Armenia
Austria
Bermuda
Brazil
Canada - Quebec
Cyprus
France
Germany
Ghana
Hong Kong
India
Japan
Jordan
Luxembourg
Netherlands
Nigeria
Norway
Panama
Philippines
Russia
South Korea
Sweden
Switzerland
Turkey
United Kingdom
United StatesFollow Getting the Deal Through for the latest updates on law and regulation worldwide
Follow us on LinkedInGTDT: Market Intelligence provides a unique perspective on evolving legal and regulatory landscapes in major jurisdictions around the world. Through engaging, easily comparable interviews, the series provides the legal profession's thought leaders with a platform for sharing their views on current market conditions and developments in the law.
Market Intelligence offers readers a highly accessible take on the crucial issues of the day and an opportunity to discover more about the people behind the most interesting cases and deals.
View profile
Established in 1825 in Dublin, Ireland and with offices in Cork, London, New York, Palo Alto and San Francisco, more than 700 people work across Matheson’s six offices, including 96 partners and tax principals and over 470 legal and tax professionals.
View more information about Matheson
Dublin
70 Sir John Rogerson’s Quay2
Dublin
Ireland T: +353 1 232 2000
F: +353 1 232 3333
Testimonials
We have received instruction from foreign counsel recently who found us through the publication
The comprehensive range of guides produced by GTDT provides practitioners with an extremely useful resource when seeking an overview of key areas of law and policy in practice areas or jurisdictions which they may otherwise be unfamiliar with.
My experience with GTDT Online so far has been wonderful. It is so useful when dealing with multijurisdictional legal matters. Two thumbs up for such a great tool and my congratulations to all of you for making my life easier.
Such a database is a fantastic tool to get access to the "basics" of many legal areas, almost everywhere. I do believe that GTDT has a real future and, according to me, it's one of the best legal database I've ever had access to in these last 10 years.
Briefing Signup
Sent approximately once a month, the free GTDT Briefing service alerts you of the latest titles to be published on GTDT Online.
Sign up to be notified of new content
SubscribeFollow Getting the Deal Through for the latest updates on law and regulation worldwide
Follow us on LinkedIn