Rome I and Rome II: A Handbook to Determine the Law Governing Contractual and Non-Contractual Obligations
October 25, 2010
By Norman Pepe
This Client Alert aims to provide in-house counsels who are involved in international transactions with an overview of the recent uniform European conflict-of-law rules governing the process by which the law applicable to contractual and to non-contractual obligations is selected.
Regulation (EC) No 864/2007 of 11 July 2007 applies to non-contractual obligations (the Rome II Regulation), and Regulation (EC) No 593/2008 of 17 June 2008 applies to contractual obligations (the Rome I Regulation and, together with the Rome II Regulation, the Rome Regulations).