A quelle loi est soumis un contrat international, à la loi française ou à une loi étrangère ?
Un contrat est international lorsqu’il contient des éléments étrangers, appelés éléments d’extranéité, tels que la nationalité des parties, le lieu du contrat ou son lieu d’exécution. Ainsi, un contrat conclu entre deux personnes de nationalité différente, ou encore situé dans deux Etats différents est un contrat international.
La matière était principalement gouvernée par la convention de Rome sur la loi applicable aux obligations contractuelles entrée en vigueur le 1er avril 1991 applicable aux contrats conclus entre le 1er avril 1991 et le 17 décembre 2009. Après cette date, il convient d’appliquer le Règlement 593/2008 du 17 juin 2008 sur la loi applicable aux obligations contractuelles. Le droit de l’UE prime le droit interne. Il convient donc de le mettre en oeuvre en France mais aussi dans les autres Etats membres avant toute autre règle interne.
Pour l’étude sur le Règlement du 17 juin 2008, suivre ce lien.
Pour l’étude sur la Convention de Rome, suivre ce lien.
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