Typically the jurisdiction clause and choice of law governing compromise agreements are English law and English courts. We are coming across situations (more and more often) where employees may be, say, American Citizens and employed by US companies to work for their UK subsidiaries in the UK and the question arises which law applies (as the employers are in the US but the companies that the employees are working for on a day to day basis are based in the UK). In one situation where we advised, the employee had two agreements – one under English law and the other agreement under US law.
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