Drawing upon modern theoretical frameworks, this book provides academics, advanced students and practitioners interested in the legal regulation of transnational employment relationships in Europe with an accessible and up-to-date account of the relevant European rules of jurisdiction and choice of law.
The European Private International Law of Employment provides a descriptive and normative account of the European rules of jurisdiction and choice of law which frame international employment litigation in the courts of EU Member States. The author outlines the relevant rules of the Brussels I Regulation Recast, the Rome Regulations, the Posted Workers Directive and the draft of the Posting of Workers Enforcement Directive, and assesses those rules in light of the objective of protection of employees. By using the UK as a case study, he also highlights the impact of the 'Europeanisation' of private international law on traditional perceptions and rules in this field of law in individual Member States. For example, the author demonstrates that the private international law of the EU is fundamentally reshaping English conflict of laws by almost completely merging the traditionally perceived contractual, statutory and tortious claims into one claim for choice-of-law purposes.
