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Litigation & Arbitration · Cross-Border

A dispute with a company
abroad?

When a commercial dispute crosses the Greek border, the first question is where and under which law it will be decided. Disputes with foreign companies and partners abroad, questions of international jurisdiction, applicable law and parallel proceedings. We support Greek businesses in cross-border commercial disputes, from the initial assessment of the case through to litigation and the recognition and enforcement of judgments.

What We Handle Discuss Your Matter
JurisdictionWhere & Under Which Law
EnforcementForeign Judgments
3Languages
Greek and English Law
Familiarity with English commercial law, which is often chosen as the governing law of international commercial contracts.
We know how international commercial relationships work
Support with the recognition and enforcement of foreign judgments in Greece and of Greek judgments abroad, under the applicable European or international framework
Parallel Proceedings · One strategy
Where the same dispute is connected with more than one country, we assess international jurisdiction, lis pendens and the relationship between the proceedings from the outset, so that a single strategy can be formed.
In dispute with a company or partner abroad?
Call us for an initial conversation about jurisdiction, the applicable law, the procedure that can be followed and the prospects for recognition and enforcement of the judgment.
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What We Handle Overview Experience FAQ Related

Scope of Service

What we handle
in cross-border disputes.

From identifying the competent court and the applicable law through to the recognition and enforcement of the judgment. We support Greek businesses in disputes with foreign companies and partners abroad, assessing from the outset where the proceedings should be brought, which law applies and how the outcome can be realised in practice. Cross-border litigation lawyers earn their fee at that stage, because the wrong forum can cost the claim entirely.

International Jurisdiction
Assessment of the appropriate forum for the dispute and support on questions of international jurisdiction, including choice of court clauses and objections to the jurisdiction of the Greek or foreign courts.
Parallel Proceedings & Lis Pendens
Handling cases where the same or a related dispute is pending in more than one country. We assess the relationship between the proceedings and the strategy to be followed on international jurisdiction and lis pendens.
Applicable Law & Private International Law
Determining the law that governs a cross-border commercial dispute, whether the claim is contractual or non-contractual. We also have experience in handling matters governed by foreign law, including proving and interpreting the foreign law and dealing with the related objections and submissions before the Greek courts.
When the dispute is governed by English law
Where a dispute turns on English law, our familiarity with English commercial law allows us to support the case before the Greek courts and, where court action is required in England, to coordinate with lawyers in London.
Recognition & Enforcement of Foreign Judgments
Support with the recognition and enforcement of foreign judgments in Greece, and with the enforcement of Greek judgments abroad. For judgments from EU Member States, the European framework of the Brussels Ia Regulation applies where they fall within its scope. For judgments from third countries, we examine the international or national framework applicable in each case.
Cross-Border Enforcement
Planning the enforcement process where the debtor or their assets are in a different country from the one in which the judgment was given. We coordinate the steps required in Greece and, where needed, with local lawyers in the country of enforcement.

Overview

When your dispute involves
more than one country.

A commercial dispute with a foreign company or partner can raise questions that never arise in a purely Greek matter: which country's courts have jurisdiction, which law applies, whether proceedings are already pending elsewhere, and where the judgment can ultimately be recognised and enforced. We assess these questions at the outset, before the route to court is chosen. We look at jurisdiction, the applicable law, any parallel proceedings and the connection between the dispute and the different legal systems, so that the litigation strategy takes into account not only where the case will be decided but also how the outcome will be realised.

Our experience covers disputes between Greek businesses and foreign companies and counterparties, as well as matters governed by foreign law. A partner of the firm is, in addition to being a lawyer in Greece, a solicitor in England, and we work with local lawyers and coordinate the international procedural strategy.

In an international dispute, the right strategy has to take account of every country connected with the matter — not only the one in which the proceedings begin.

Obtaining a judgment does not always bring a cross-border dispute to an end. Where the debtor or their assets are in another country, how the judgment can be recognised and enforced there has to be considered from the start. We support the recognition and enforcement of foreign judgments in Greece, and the enforcement of Greek judgments abroad, working with lawyers in the relevant jurisdiction where required. At the same time we look at where the assets are, the applicable framework for recognition and enforcement, and the procedural steps required in the country where the assets are located.

Experience in Matters Governed by Foreign Law
When the dispute is governed by English law
Our familiarity with English law gives a real advantage where a Greek business is in dispute with an English or other foreign company before the Greek courts.

Experience

in disputes with
a foreign element

English Law · Practical Experience
When the dispute is governed by English law
Our familiarity with English law gives us a real advantage where a Greek business is in dispute with an English or other foreign company before the Greek courts.
International Trade · In-House Experience
We know how international commercial relationships work
A partner of the firm served for eleven years as General Counsel of a Fortune 50 technology group, with responsibility for four business divisions across eight countries. That experience covers cross-border contracts, commercial relationships and the disputes that arise in an international business environment.
Experience in Matters Governed by Foreign Law
Foreign law does not stop the Greek proceedings
We have experience in handling matters before the Greek courts in which foreign law applies, including questions of proving and interpreting the content of that foreign law and the related objections.
Asset Strategy
Recognition & Enforcement in Greece
We have advised a foreign shipowner on the recognition and enforcement in Greece of a judgment given outside the EU, and on the proceedings that followed in relation to that judgment.
Experience Highlight
Recognition of a foreign judgment in Greece
We advised a foreign company on the recognition and enforcement in Greece of a judgment given outside the EU against a Greek shipowner, and on the proceedings that followed in relation to that judgment.

Frequently Asked Questions

Questions about
cross-border disputes.

How is a foreign judgment recognised and enforced in Greece?+

It depends on the country in which the judgment was given and on the international or European framework that applies. For judgments given in another EU Member State that fall within the scope of the Brussels Ia Regulation, the judgment is recognised and can be enforced in Greece without a separate declaration of enforceability. The Regulation does, however, provide limited grounds on which refusal of recognition or enforcement may be sought. For judgments from third countries, the applicable Greek or international framework is examined, including any bilateral or multilateral conventions. The procedure and the conditions for recognition and enforcement therefore depend on the particular country of origin and on the nature of the judgment.

What is the difference between enforcing an EU judgment and a non-EU judgment?+

For judgments given in another EU Member State that fall within the scope of the Brussels Ia Regulation, a simplified regime of recognition and enforcement applies. The judgment is recognised without any special procedure and, provided it is enforceable in the state of origin, it can be enforced in Greece without a prior declaration of enforceability. The enforcement process is then governed by Greek law, subject to the limited grounds of refusal provided for in the Regulation. For judgments from countries outside the EU the regime is different and depends on the particular country of origin, on any international or bilateral convention and on the rules of Greek private international law. The applicable framework and the procedure required for the recognition and enforcement of the particular judgment in Greece therefore have to be determined first.

What happens when proceedings are started in two countries at the same time?+

This is a question of international lis pendens. Depending on the countries involved and the rules that apply, the court seised second may have to stay its proceedings in favour of the court seised first. For that reason, international jurisdiction and the relationship between the proceedings should be examined from the outset, so as to limit the risk of conflicting judgments and the unnecessary burden of time and cost.

Can a Greek judgment be enforced against assets abroad, for example in England?+

Yes. Subject to the conditions of the applicable law, a Greek judgment can be recognised and enforced in England and Wales, or in another country where the debtor has assets. Since Brexit, the procedure in England is no longer based on the Brussels Ia regime and has to be considered under the English or international framework now in force.

In dispute with a foreign business?

Tell us the essentials of the matter and we will look at jurisdiction, the applicable law and the options available to you.

Contact +30 210 36 33 694