The mutual recognition and enforcement of judgments in civil and commercial matters between the UK and the Netherlands used to be governed by the Brussels Recast Regulation. Today, post-Brexit, it is not an easy task to determine which rules apply. The key issue is whether the Convention between the Kingdom of the Netherlands and the United Kingdom of Great Britain and Northern Ireland providing for the Reciprocal Recognition and Enforcement of Judgments in Civil Matters dated 17 November 196711 revived. Nonetheless, a notable exception to the current uncertainty exists with respect to judgments that fall within the scope of the Hague Convention on Choice of Court Agreements dated 30 June 20052.
Gregorio Ruggeri-Laderchi is an associate in the Amsterdam Dispute Resolution Practice Group.