contrat d’agent commercial international : juridiction compétente

contrat d’agent commercial international : juridiction compétente

  • Posted by admin
  • On 2 juillet 2013
  • 5763 Comments

La Cour de cassation a rendu le 14 mai 2013 un nouvel arrêt relatif à la compétence des juridictions en matière de contrat  d’agent commercial international.En 1994, une société italienne avait conclu un contrat d’agence commerciale à titre exclusif avec une personne physique pour la distribution en Europe des jouets. L’agent avait exercé son activité en Belgique jusqu’à sa substitution par une société belge en 1997. Le contrat avait ensuite été exécuté jusqu’en 2001, année au cours de laquelle un nouveau contrat avait été conclu par la société italienne avec une société luxembourgeoise.

En 2008, il avait été mis fin à ce dernier contrat, ce qui a conduit l’agent commercial luxembourgeois à assigner la société italienne devant le tribunal de commerce de Beauvais en paiement d’une indemnité de rupture et en réparation du préjudice résultant de la non-participation de la société italienne à un salon du jouet.

                                                                  droit-communautaire

La société italienne a soulevé l’incompétence territoriale de ce tribunal au profit des juridictions belges ou luxembourgeoises. Le tribunal s’est alors déclaré incompétent. Suite à un contredit jugé mal fondé par la Cour d’appel de Reims, un pourvoi a été formé devant la Cour de cassation.

Selon la Cour d’appel, à défaut de stipulation contractuelle précisant le lieu d’exécution de la prestation de service, les activités d’agent exclusif avaient été effectivement exercées de manière prépondérante en Belgique par les deux premiers agents et en Belgique et au Luxembourg par le dernier. La Cour de cassation ajoute que la Cour d’appel « ayant ainsi fait ressortir que le lieu de la fourniture principale de services de la société BSM telle qu’elle découlait de l’exécution effective du contrat, comme du lieu où celle-ci était domiciliée, ne pouvait être localisé en France ». En conséquence, la Cour de cassation rejette le pourvoi formé contre cet arrêt qui avait retenu l’incompétence de la juridiction française » (Cass. Com., 14 mai 2013, N° 11-26631).

Cette décision est-elle conforme à la jurisprudence de la CJUE telle que développée, sur le fondement de l’article 5 1) b) du Règlement n° 44/2001 du 22 décembre 2000 concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale, dans l’arrêt Wood Floor Solutions Andreas Domberger GmbH (CJCE, 11 mars 2010, Affaire C-19/09)? La formule de la Cour de cassation est ambiguë. Si elle approuve la Cour d’appel d’avoir retenu le lieu du domicile de l’agent commercial comme lieu effectif de la fourniture de service, elle n’est pas conforme. En revanche, si elle considère que ce lieu devait être retenu parce qu’il était impossible de déterminer le lieu principal de la fourniture de services, alors elle est conforme. La formule incline à privilégier la première interprétation.

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