[LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

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[LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
Where is the business based?


Kind regards,

Paul



Paul Kelly
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r
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This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
For tax and law points of view there are 3 points to identify which law should follow 

1. Where is the company registered 
2. Where is the income from, e.g you sell goods/services to us that make you operation from U.K. So follow U.K. Rules, other ways round need to follow U.S because when you exporting services/goods to other countries they have there own tax and laws to protect their country 
3. The nationality of the director and shareholder of the company.





Sent from my iPhone

On 27 Jul 2017, at 21:37, Wei Leng <[hidden email]> wrote:

Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




--
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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
It may depend on the contract, however, if you have a dispute, it will be easier and cheaper for you to fight it here.


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:37, Wei Leng <[hidden email]> wrote:
Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
So there are no physical goods or services involved. The product is digital and made available worldwide. I have read about putting in a clause about going into arbitration. 
But I’m not sure if anyone has had experience with this. Is it a good idea? Is it expensive to enforce? What are the pitfalls and who would the arbiter be?

It’s a simple agreement but made so complex because it’s cross-borders.

On Thu, 27 Jul 2017 at 22:00, Paul Kelly <[hidden email]> wrote:
It may depend on the contract, however, if you have a dispute, it will be easier and cheaper for you to fight it here.


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:37, Wei Leng <[hidden email]> wrote:
Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
I routinely specify expedited arbitration rather than courts when the value of the contract is above a certain threshold, and full arbitration above another threshold.

In Scandinavia, even government contracts tend to specify arbitration rather than the courts for speed, confidentiality, flexibility and also cost, which can be lower for high value contracts.

There is a number of arbitration centres around the world. The main one is in Paris with the one in London not far after. They are both good but also quite expensive to use. I use the Arbitration Institute of the Stockholm Chamber of Commerce in most of Europe and specify that the language used should be English. They will use whatever law is stated in the contract. Their fees are far lower than in London or Paris and they are internationally recognised (second largest in the world for investment arbitration).




On 27 Jul 2017, at 23:13, Wei Leng <[hidden email]> wrote:

So there are no physical goods or services involved. The product is digital and made available worldwide. I have read about putting in a clause about going into arbitration. 
But I’m not sure if anyone has had experience with this. Is it a good idea? Is it expensive to enforce? What are the pitfalls and who would the arbiter be?

It’s a simple agreement but made so complex because it’s cross-borders.

On Thu, 27 Jul 2017 at 22:00, Paul Kelly <[hidden email]> wrote:
It may depend on the contract, however, if you have a dispute, it will be easier and cheaper for you to fight it here.


Kind regards,

Paul



Paul Kelly
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r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
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London W6 9PX






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On 27 July 2017 at 21:37, Wei Leng <[hidden email]> wrote:
Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
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r
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43 The Square
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On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote:
I’m based in the UK. Looking to do a deal with someone based in the US.

On Thu, 27 Jul 2017 at 21:25, Paul Kelly <[hidden email]> wrote:
Where is the business based?


Kind regards,

Paul



Paul Kelly
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r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank" class="">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank" class="">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






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On 27 July 2017 at 21:19, Wei Leng <[hidden email]> wrote:
Question:

When you have a commercial agreement (profit-sharing agreement) between 2 entities; (one based in the UK and another based in US), should the agreement be drafted under UK law or US law?

Does anyone here know?

Thanks!

Kind regards
Wei Leng Pointen




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Re: [LondonOpenCoffee] Commercial Agreement: Which Law jurisdiction?

Ajit
In reply to this post by Ajit
Robert

This is golden- Thank you so much!

On Thu, 27 Jul 2017 at 22:30, Robert Claeson <[hidden email]> wrote:
I routinely specify expedited arbitration rather than courts when the value of the contract is above a certain threshold, and full arbitration above another threshold.

In Scandinavia, even government contracts tend to specify arbitration rather than the courts for speed, confidentiality, flexibility and also cost, which can be lower for high value contracts.

There is a number of arbitration centres around the world. The main one is in Paris with the one in London not far after. They are both good but also quite expensive to use. I use the Arbitration Institute of the Stockholm Chamber of Commerce in most of Europe and specify that the language used should be English. They will use whatever law is stated in the contract. Their fees are far lower than in London or Paris and they are internationally recognised (second largest in the world for investment arbitration).




On 27 Jul 2017, at 23:13, Wei Leng <[hidden email]> wrote:

So there are no physical goods or services involved. The product is digital and made available worldwide. I have read about putting in a clause about going into arbitration. 
But I’m not sure if anyone has had experience with this. Is it a good idea? Is it expensive to enforce? What are the pitfalls and who would the arbiter be?

It’s a simple agreement but made so complex because it’s cross-borders.

On Thu, 27 Jul 2017 at 22:00, Paul Kelly <[hidden email]> wrote:
It may depend on the contract, however, if you have a dispute, it will be easier and cheaper for you to fight it here.


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - 020 3011 5600
Mobile - 07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:37, Wei Leng <[hidden email]> wrote:
Paul

Thanks. It will be between 2 companies. One incorporated in the UK and the other incorporated in  the US. Are there any considerations to bear in mind when making these negotiations; ie why is it beneficial for me to have it drafted under English laws?

On Thu, 27 Jul 2017 at 21:32, Paul Kelly <[hidden email]> wrote:
So, there is no business, it is a personal agreement?

I would have it in the UK, but it could go to either or somewhere neutral.  It is for you to negotiate!


Kind regards,

Paul



Paul Kelly
Chief Helpe
r
Office - <a href="tel:020%203011%205600" value="+442030115600" target="_blank">020 3011 5600
Mobile - <a href="tel:07850%20350627" value="+447850350627" target="_blank">07850 350627
Skype - paul.kelly
Follow me on twitter - icanhelpyourbiz



43 The Square
Hammersmith
London W6 9PX






This e-mail and any attachments are intended for a specific recipient and may be confidential. If you have received it in error you must not forward, copy or show it anyone, returning it to the sender and then deleting it from your system.

On 27 July 2017 at 21:30, Wei Leng <[hidden email]> wrote: