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Jurisdiction(s):
Ireland

Ireland cross-border litigation: applicable law, jurisdiction, enforcement, Rome I/II, Brussels I Recast, Lugano Convention, Hague Convention, and post-Brexit UK considerations, including anti-suit injunctions

Practice notes
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Practice Note

This Practice Note sets out the practical considerations that arise when handling cross-border litigation in Ireland. It reviews questions of applicable law and jurisdiction within the boundaries of the EU’s legal regime. It also surveys the position after Brexit and the consequences this shift has had for cross-border disputes. This Practice Note is intended to clarify the real-world issues practitioners should weigh when proceedings involve international elements in or connected to Ireland. It examines choice of law and forum within the structure of EU rules, and reflects on the post-Brexit environment and its effects on cross-border disputes. Where a claim has a cross-border dimension - whether because parties are based in different states or because material events occurred in another country or countries - parties and their advisers must focus on three central questions:

  • jurisdiction - in which country should the claim be commenced?
  • applicable law - which country’s laws will the court apply when hearing the substantive dispute?
  • enforcement - where can any judgment obtained be enforced?

This Practice Note considers applicable law and jurisdiction under the EU framework, and evaluates the post-Brexit landscape and effect on cross-border disputes...

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Natalie Quinlivan
Natalie Quinlivan

Natalie is a dual-qualified litigator (Rep. of Ireland and England and Wales) with an international practice that focuses on complex disputes and corporate investigations. Natalie has extensive dispute resolution experience with a particular focus on joint venture and shareholder disputes, directors' duties and misfeasance claims, as well as civil fraud, international asset-tracing and enforcement cases. In addition to her litigation practice, Natalie is a corporate investigations and risk advisory specialist. She advises clients on the full breadth of financial crime issues, from educating c-suite executives to sales teams on best practice preventative action, through to running internal and regulatory investigations. She has acted on a number of high profile cross border investigations involving bribery and corruption allegations, money laundering breaches and dawn raids. Natalie's client base operates predominantly in the EMEA and APAC regions and includes domestic and global organisations in the financial services, oil and gas, green...

Web page updated on 22/05/2026

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