JURISDICTION · CONTINENTAL EUROPE
Cross-Border
Legal Counsel in France
Cross-border M&A, commercial disputes, and enforcement involving French parties — with particular focus on FDI screening and the post-closing conflicts that follow complex French deals.
Since 2011
boutique international counsel
boutique international counsel
Partner-led
one partner owns your matter
one partner owns your matter
35+
jurisdictions covered
jurisdictions covered
France is a frequent jurisdiction in VLO's Continental European work, both as a transaction venue and as a dispute forum. We advise on acquisitions of French targets, foreign-investment screening under the French control regime, and the post-closing disputes that often follow complex French deals. On the contentious side, France's position as one of the world's leading arbitration centres means a high proportion of the awards we enforce, and the proceedings we coordinate, have a Paris connection.
Our Continental Europe desk handles French matters with the language fluency and procedural familiarity that French practice demands. France's legal culture is distinct — formal, document-driven, and procedurally exacting — and a foreign party who approaches it casually tends to lose ground early. We treat the French component as one coordinated part of a wider strategy rather than an isolated instruction.
Most French matters that reach us are not purely French. A French target sits inside a multinational acquisition; a Paris-seated award needs enforcement against assets in several countries; a French subsidiary is one entity in a group dispute. Coordinating the French element with the rest — under one partner who sees the whole map — is the core of what we deliver.
Our Continental Europe desk handles French matters with the language fluency and procedural familiarity that French practice demands. France's legal culture is distinct — formal, document-driven, and procedurally exacting — and a foreign party who approaches it casually tends to lose ground early. We treat the French component as one coordinated part of a wider strategy rather than an isolated instruction.
Most French matters that reach us are not purely French. A French target sits inside a multinational acquisition; a Paris-seated award needs enforcement against assets in several countries; a French subsidiary is one entity in a group dispute. Coordinating the French element with the rest — under one partner who sees the whole map — is the core of what we deliver.
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VLO IN FRANCE
Send a France brief
How we work in France
LEGAL SYSTEM
What foreign parties need to know about France
France is the archetypal civil-law jurisdiction. Its civil and commercial codes form the backbone of private law, and procedure is codified and document-centred. Civil disputes are decided by professional judges; there is no civil jury. For a foreign party, the most important structural feature is the division between the ordinary civil courts and the specialised Commercial Courts (Tribunaux de commerce), which hear most business disputes and whose judges are themselves drawn from the commercial world.
The court structure runs from first-instance courts through the Courts of Appeal (Cours d'appel) to the Court of Cassation (Cour de cassation), France's highest court for civil and commercial matters, which reviews points of law rather than re-trying facts. Understanding which court a dispute belongs in, and how the appeal structure shapes settlement leverage, is part of the early strategic work.
France's foreign-investment screening regime is among the more active in Europe. The government can review and condition acquisitions of French companies in sensitive and strategic sectors, and the scope of what counts as sensitive has broadened in recent years. For a non-EU buyer, this can materially affect both the timeline and the structure of a transaction, and it must be planned for from the outset rather than discovered late in the deal.
France has also developed English-language international commercial chambers within the Paris court system, designed to attract cross-border disputes that might otherwise default to London. For foreign parties, this is a meaningful option, though the underlying procedure and substantive law remain French.
A further point of practical importance is the role of the juge de la mise en état and the structured pre-trial phase in French civil procedure, which front-loads the organisation of the case. For a foreign litigant, this means the early procedural posture — the framing of claims, the timetable for submissions, the management of evidence — carries more weight than in systems where matters crystallise closer to trial. Engaging with that structure correctly from the outset shapes the whole proceeding.
The court structure runs from first-instance courts through the Courts of Appeal (Cours d'appel) to the Court of Cassation (Cour de cassation), France's highest court for civil and commercial matters, which reviews points of law rather than re-trying facts. Understanding which court a dispute belongs in, and how the appeal structure shapes settlement leverage, is part of the early strategic work.
France's foreign-investment screening regime is among the more active in Europe. The government can review and condition acquisitions of French companies in sensitive and strategic sectors, and the scope of what counts as sensitive has broadened in recent years. For a non-EU buyer, this can materially affect both the timeline and the structure of a transaction, and it must be planned for from the outset rather than discovered late in the deal.
France has also developed English-language international commercial chambers within the Paris court system, designed to attract cross-border disputes that might otherwise default to London. For foreign parties, this is a meaningful option, though the underlying procedure and substantive law remain French.
A further point of practical importance is the role of the juge de la mise en état and the structured pre-trial phase in French civil procedure, which front-loads the organisation of the case. For a foreign litigant, this means the early procedural posture — the framing of claims, the timetable for submissions, the management of evidence — carries more weight than in systems where matters crystallise closer to trial. Engaging with that structure correctly from the outset shapes the whole proceeding.
ENFORCEMENT & RECOGNITION
Enforcing judgments and awards in France
Enforcement in France depends on the origin of the judgment or award. For civil and commercial judgments from other EU member states, recognition and enforcement run through the Brussels Ia Regulation (Recast): a qualifying judgment can be enforced without separate exequatur proceedings, with the debtor bearing the burden of raising the limited grounds for refusal, such as a genuine public-policy conflict or defective service.
For arbitral awards, France is a leading pro-arbitration jurisdiction and a long-standing party to the New York Convention. French courts apply the Convention's narrow refusal grounds and have a well-developed body of practice supporting the recognition and enforcement of foreign awards. France's arbitration-friendly stance is one reason Paris is chosen as a seat so often.
For judgments from outside the EU and outside any applicable treaty, France applies its own rules on the recognition of foreign judgments, examining the jurisdiction of the originating court, the regularity of the proceedings, and consistency with French public policy. This route is more involved and requires careful preparation.
As everywhere, the legal test is rarely the obstacle. The real work is locating enforceable assets in France, sequencing the application to prevent dissipation, and anticipating the procedural defences a sophisticated debtor will deploy. Where dissipation is a risk, French procedure offers protective measures that can be sought to secure assets, and moving early — before the debtor is alerted — is often decisive.
A practical point specific to France concerns provisional and protective measures. French procedure allows a creditor to seek conservatory attachment (saisie conservatoire) over a debtor's assets — bank accounts, receivables, movable and immovable property — to secure a claim before or during proceedings, and obtaining such a measure early, before the debtor reacts, frequently determines whether an eventual judgment can be realised. We assess the availability of these measures at the scoping stage where dissipation is a concern.
For arbitral awards, France is a leading pro-arbitration jurisdiction and a long-standing party to the New York Convention. French courts apply the Convention's narrow refusal grounds and have a well-developed body of practice supporting the recognition and enforcement of foreign awards. France's arbitration-friendly stance is one reason Paris is chosen as a seat so often.
For judgments from outside the EU and outside any applicable treaty, France applies its own rules on the recognition of foreign judgments, examining the jurisdiction of the originating court, the regularity of the proceedings, and consistency with French public policy. This route is more involved and requires careful preparation.
As everywhere, the legal test is rarely the obstacle. The real work is locating enforceable assets in France, sequencing the application to prevent dissipation, and anticipating the procedural defences a sophisticated debtor will deploy. Where dissipation is a risk, French procedure offers protective measures that can be sought to secure assets, and moving early — before the debtor is alerted — is often decisive.
A practical point specific to France concerns provisional and protective measures. French procedure allows a creditor to seek conservatory attachment (saisie conservatoire) over a debtor's assets — bank accounts, receivables, movable and immovable property — to secure a claim before or during proceedings, and obtaining such a measure early, before the debtor reacts, frequently determines whether an eventual judgment can be realised. We assess the availability of these measures at the scoping stage where dissipation is a concern.
DISPUTE RESOLUTION FORUMS
Where France disputes are resolved
Paris is one of the world's foremost arbitration seats and the home of the International Chamber of Commerce, whose International Court of Arbitration administers a large share of global institutional arbitration. For a foreign party, a Paris seat offers a sophisticated arbitral culture and a supervisory judiciary — the Paris Court of Appeal has specialised arbitration chambers — that supports rather than undermines the process.
For litigation, the specialised Commercial Courts handle most business disputes, and the international commercial chambers within the Paris court system allow certain cross-border matters to be conducted substantially in English. The choice between arbitration and litigation in France turns on confidentiality, the need for a cross-border-enforceable outcome, the governing law, and the realistic timetable — a choice we work through with clients rather than defaulting to the familiar.
A further consideration is the interaction between the two forums. Even where a contract provides for arbitration, the French courts retain a supporting role — for interim measures before a tribunal is constituted, for assistance with evidence, and ultimately for enforcement of the award. France's pro-arbitration judiciary means this supporting role is exercised constructively rather than as an avenue for obstruction, which is part of why a French seat is attractive.
For litigation, the specialised Commercial Courts handle most business disputes, and the international commercial chambers within the Paris court system allow certain cross-border matters to be conducted substantially in English. The choice between arbitration and litigation in France turns on confidentiality, the need for a cross-border-enforceable outcome, the governing law, and the realistic timetable — a choice we work through with clients rather than defaulting to the familiar.
A further consideration is the interaction between the two forums. Even where a contract provides for arbitration, the French courts retain a supporting role — for interim measures before a tribunal is constituted, for assistance with evidence, and ultimately for enforcement of the award. France's pro-arbitration judiciary means this supporting role is exercised constructively rather than as an avenue for obstruction, which is part of why a French seat is attractive.
WHEN CLIENTS COME TO US
Common France scenarios
ACQUISITION OF A FRENCH TARGET
You are acquiring a French company and need foreign-investment screening coordinated with antitrust clearance and a timeline that holds the deal together. We manage the French regulatory pathway and the transaction documents in parallel.
POST-CLOSING DISPUTE
An earn-out, warranty, or representations dispute has emerged after a French deal. We act in the relevant forum, drawing on familiarity with both the transaction context and French dispute procedure.
PARIS-SEATED ARBITRATION
You hold or are defending an award seated in Paris, or your contract contains an ICC clause. We act as counsel and coordinate any related French court applications.
ENFORCEMENT AGAINST FRENCH ASSETS
You need to recover against assets in France. We coordinate recognition under Brussels Ia or the New York Convention and move to execution, securing protective measures where dissipation is a risk.
ILLUSTRATIVE MATTER
What a France engagement looks like
SECTORS & MATTER TYPES
The France matters we see most
The French matters that reach us concentrate in a few areas. Cross-border M&A is the largest: acquisitions of French targets by European and non-EU buyers, where foreign-investment screening and antitrust clearance must be sequenced into the deal, and where the post-closing disputes — earn-outs, warranties, representations — frequently follow. France's active screening regime makes early regulatory planning essential for non-EU acquirers.
A second cluster is arbitration and award enforcement, driven by Paris's status as a global seat. We act as counsel in ICC and ad hoc proceedings and coordinate the enforcement of Paris-seated awards against assets in multiple jurisdictions. A third is commercial litigation arising from French-law contracts and distribution, supply, and agency relationships, heard before the Commercial Courts.
We do not handle routine French domestic matters, consumer disputes, or high-volume collection. Our work is the complex cross-border dispute or transaction where the French component sits inside a larger international picture and warrants partner-level attention.
Within these clusters, certain sectors recur: luxury and consumer goods, aerospace and defence (where the foreign-investment regime is most active), energy and infrastructure, and technology. The defence and strategic-sector dimension is particularly relevant because it is precisely where French foreign-investment screening bites hardest, and where a non-EU acquirer most needs early, coordinated regulatory planning.
A second cluster is arbitration and award enforcement, driven by Paris's status as a global seat. We act as counsel in ICC and ad hoc proceedings and coordinate the enforcement of Paris-seated awards against assets in multiple jurisdictions. A third is commercial litigation arising from French-law contracts and distribution, supply, and agency relationships, heard before the Commercial Courts.
We do not handle routine French domestic matters, consumer disputes, or high-volume collection. Our work is the complex cross-border dispute or transaction where the French component sits inside a larger international picture and warrants partner-level attention.
Within these clusters, certain sectors recur: luxury and consumer goods, aerospace and defence (where the foreign-investment regime is most active), energy and infrastructure, and technology. The defence and strategic-sector dimension is particularly relevant because it is precisely where French foreign-investment screening bites hardest, and where a non-EU acquirer most needs early, coordinated regulatory planning.
HOW COORDINATION WORKS
One partner, one strategy — across every jurisdiction
The coordination model is central to the value we deliver in France. One VLO partner owns the strategy and the client relationship for the entire matter; any French local counsel or specialists engaged act under that partner's instructions and report through us, not directly to you in uncoordinated parallel streams. Our Continental Europe desk handles the substantive French proceedings with the requisite language and procedural fluency.
This matters most when a French matter spans borders — which is the norm. The failure we are most often asked to rescue is the client who instructed separate firms across several countries, none owning the overall strategy, producing parallel proceedings that work against each other and inconsistent positions. Treating France as one coordinated part of a single mandate avoids that.
This matters most when a French matter spans borders — which is the norm. The failure we are most often asked to rescue is the client who instructed separate firms across several countries, none owning the overall strategy, producing parallel proceedings that work against each other and inconsistent positions. Treating France as one coordinated part of a single mandate avoids that.
OUR APPROACH
How a France matter is run
France rewards procedural formality and early regulatory planning. We scope the French issues alongside every other jurisdiction in play, deliver a strategy memo with a procedural map and fee structure within five business days, run the French proceedings through our Continental Europe desk, and report to you in English with consolidated updates.
SCOPING
Map the France issues and any other jurisdictions involved
STRATEGY MEMO
Procedural map, merits, fees — within 5 business days
EXECUTION
Continental Europe desk leads; local counsel coordinated by VLO
RESOLUTION
Settlement, award, or judgment — reported in English
Elena Moretti
Matters in France are coordinated through the Continental Europe desk. For a matter routed to Elena, use the main contact form — enquiries are routed by jurisdiction and practice area.
PARTNER · CONTINENTAL EUROPE
EM
FRANCE DESK LEAD
WHY VLO FOR FRANCE
What we bring to a France matter
France combines an active foreign-investment screening regime, a sophisticated and formal commercial court system, and the world's leading arbitration centre. Each of these rewards specialist handling: the screening regime because timing and structure must be planned early; the courts because French procedure is exacting and unforgiving of casual approaches; the arbitration because Paris practice has its own deep body of law.
VLO's value in France is handling the transactional, regulatory, and dispute components through a single coordinated relationship — so that the team that managed the FDI clearance understands the post-closing dispute that follows, and the partner who runs the Paris arbitration sees how the award will be enforced elsewhere.
For General Counsel and CFOs, this means one accountable relationship for the French component of a cross-border matter, transparent fees agreed at the outset, and the discretion that sensitive commercial disputes require.
There is also a strategic dimension to France's dual role as both a transaction and a dispute jurisdiction. Because the same matters that generate French acquisitions later generate French post-closing disputes, continuity matters: a team that understood the FDI clearance and the SPA negotiation is materially better placed to run the earn-out or warranty dispute that follows. We are structured to provide that continuity rather than treating the transaction and the dispute as unrelated mandates handled by different firms.
VLO's value in France is handling the transactional, regulatory, and dispute components through a single coordinated relationship — so that the team that managed the FDI clearance understands the post-closing dispute that follows, and the partner who runs the Paris arbitration sees how the award will be enforced elsewhere.
For General Counsel and CFOs, this means one accountable relationship for the French component of a cross-border matter, transparent fees agreed at the outset, and the discretion that sensitive commercial disputes require.
There is also a strategic dimension to France's dual role as both a transaction and a dispute jurisdiction. Because the same matters that generate French acquisitions later generate French post-closing disputes, continuity matters: a team that understood the FDI clearance and the SPA negotiation is materially better placed to run the earn-out or warranty dispute that follows. We are structured to provide that continuity rather than treating the transaction and the dispute as unrelated mandates handled by different firms.
PARTNER OWNERSHIP
France is handled as part of the wider strategy, not as an isolated engagement.
CROSS-BORDER COORDINATION
TRANSPARENT FEES
Confidential by default. No press without explicit consent.
DISCRETION
FREQUENTLY ASKED · FRANCE
Common questions about France matters
Does VLO handle French foreign-investment screening?
Yes. Paris is one of our most frequent arbitration seats. We act as counsel in ICC and ad hoc proceedings and coordinate any related French court applications, including enforcement of the resulting award against assets elsewhere.
Can you act in Paris-seated arbitration?
How are French commercial disputes decided?
France has established English-language international commercial chambers within the Paris court system for certain cross-border matters. The underlying procedure and substantive law remain French. We advise on whether this option fits a given dispute.
Can proceedings be conducted in English?
Do you work in French?
Within the EU, recognition runs through Brussels Ia without separate exequatur. For non-EU judgments, France applies its own recognition procedure examining jurisdiction, regularity, and public policy. We coordinate either route and the subsequent execution.
Can you enforce a foreign judgment against French assets?
RELEVANT PRACTICES IN FRANCE
How we help in France
Mergers & Acquisitions matters with a France dimension.
Litigation & Arbitration matters with a France dimension.
Enforcement of Foreign Judgments matters with a France dimension.
RELATED JURISDICTIONS
Matters in France often connect with