The European Private International Law of Employment

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.

• Demonstrates how the goals and policies of the European Union, in particular the protection of employees, are fundamentally reshaping the regulation of transnational private relations • Presents new insights about the influence of EU private international law on the Member States' domestic private international law regimes, and offers recommendations for improving the existing rules of jurisdiction and choice of law • Separate examinations of the choice-of-law treatment of claims based on breach of employment contract, statute and in tort make this an accessible explanation of choice-of-law issues arising in connection with the three main types of employment claim