ARTICLE · 29 OCTOBER 2003

Bidding UK law ‘adieu’?

Gide Loyrette Nouel A.A.R.P.I.

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FranceEmployment and HR

Article by Philippe Desprès and Sébastien Le Coeur

Foreign employees posted to France often successfully claim that French law governs their employment contracts. Philippe Desprès and Sébastien Le Coeur of Gide Loyrette Nouel examine the issues for UK employers.

In spite of increasing convergence in the employment laws of the EU member states, and growth in employees’ international mobility, significant disparity persists in the treatment of employees in different European countries. In this respect, the law governing the employment relationship in accordance with the EC Convention on the Law Applicable to Contractual Obligations (the Rome Convention) continues to raise practical problems.

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