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ARTICLE · 30 MARCH 2021

Making A UK Money Judgment Enforceable In Italy

As of 31 December 2020, the United Kingdom is no longer an EU Member State. This means that the United Kingdom is a third country for the purpose of the Brussels Recast Regulation 1215/2012 (Brussels Recast).

United KingdomGovernment, Public Sector

The impact of "Brexit" on the legal framework

As of 31 December 2020, the United Kingdom is no longer an EU Member State. This means that the United Kingdom is a third country for the purpose of the Brussels Recast Regulation 1215/2012 (Brussels Recast).

The EU-UK Trade and Cooperation Agreement establishing the terms of UK's 'so called Brexit deal' does not include any provisions at all on jurisdiction and enforcement of judgments in civil cases.

It had generally been anticipated that the Brexit deal might provide for the UK's accession to the Lugano Convention 2007 to be completed in time for the end of the Brexit transition period. The Lugano Convention 2007 is very similar to Brussels Recast but the latter has the advantage of dispensing with formalities that are necessary to make the foreign judgment enforceable. The UK applied to join the Lugano Convention 2007 on 8 April 2020, but so far, the EU (which has a veto over the UK's accession) has not

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