Paris, Frankfurt Try to Grab Lucrative Legal Action From London

For decades, London has been the place to go for big commercial disputes in Europe. Even when companies based outside Britain sue one another, the cases are argued in London, such as one brought by UBS AG against Leipzig’s water utility and another by Franco-Belgian bank Dexia SA against the Italian city of Prato. With Britain preparing for Brexit, European judicial systems are trying to lure those cases to their own courts—by copying some U.K. legal practices and even offering proceedings in English. “At least one European country has to be able to process international commercial litigation,” says Guy Canivet, a former chief justice of the French Supreme Court who wrote a report on Paris’s jurisdiction post-Brexit. “It’s a matter of sovereignty.”

Paris, Amsterdam, Frankfurt, and Brussels are stepping up efforts to get a greater share of court levies and lawyers’ fees from corporate squabbles, setting up special panels that will work in the lingua franca of global business. When signing deals, companies typically agree on the jurisdiction that will hear potential disputes, and London became a leading destination because of its role as the capital of global finance and because its rulings are valid across the European Union—an advantage that could evaporate once Britain leaves the bloc. “London is stepping into the shadows,” says Roman Poseck, president of the appeals court in Frankfurt, where officials plan to have an English-language panel in place by January. “Frankfurt wants a piece of the pie.”