⚖️ What is “choice of law” and “jurisdiction”?

• Choice of law determines which country’s legal rules will govern the contract.

• Jurisdiction determines which court has authority to decide a dispute.

It may seem like a formality – but it’s a critical point that can drastically impact your chances in a legal battle.

🧭 Why it matters

• 📌 Costs and access: Foreign courts mean higher expenses, language barriers, and the need for local legal representation.

• 📌 Risk of unfamiliar law: Every country has different legal standards. A contract governed by foreign law may be interpreted very differently.

• 📌 Leverage: If you don’t define the applicable law and jurisdiction, you may end up under a system that puts you at a disadvantage.

📌 Real-world example:

A Czech entrepreneur signed a contract with a French company. The agreement lacked any jurisdiction clause. When a dispute arose, the French court declared itself competent – and applied French law. Though the Czech party was legally right, the French legal framework didn’t support his case.

✅ Lawyer’s recommendation:

For any business contract with an international element (different country, language, or company registration), always clearly state:

• which legal system governs the contract

• which court has jurisdiction to resolve disputes

You may also consider arbitration – it has pros and cons that must be evaluated case by case.