English Commercial Law – Common Law and Civil Law
It is important to understand that legal jurisdictions can be categorized as either civil law or common law jurisdictions when dealing with cross-border business transactions. Although the two countries' core components are similar, a commercial lawyer needs to be aware of their unique qualities. A second challenge for attorneys in the UK is that, although if their country has a common law system, they still need to have a working understanding of civil law systems to represent clients doing business in the EU, which is a country with many parallels to civil law countries. EU legislation will continue to have a big impact even after Brexit. Equally, as many international transactions are handled by UK or American law (another common law jurisdiction), lawyers from civil law jurisdictions engaged in international trade must be knowledgeable with common law systems. The majority of Arab nations, the former French Indo-China, Latin and South America, Russia, Japan, Turkey, South Korea, China, South Africa, and Sri Lanka are among the nations that practice civil law. Other civil law nations include many European nations like France, Belgium, Luxembourg, Spain, Italy, Germany, and Switzerland. Louisiana and Quebec in North America and Canada both have civil law systems. Keep in mind that these countries' civil laws differ from one another in many ways. Common law nations include former British colonies like England and Wales, the USA (except for Louisiana), Canada (except for Quebec), Australia, New Zealand, India, Pakistan, Ireland, several African nations, Hong Kong, the Cayman Islands, and Gibraltar, among others.
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