Cross-border legal expertise: France and the UK
Operating across France and the UK requires experts who understand both legal systems — not just one. At Lexternal, our legal professionals are qualified and experienced in both jurisdictions, advising you without the need for two separate law firms.
Book a discovery callBrexit changed the rules — permanently
Since January 2021, businesses operating across France and the UK face a new legal reality: separate regulatory regimes, new customs and VAT rules, changed employment rights, and data transfer restrictions between the UK and EU.
Companies that set up their cross-border structures before Brexit often find they need to be revisited. We audit your current setup and recommend the adjustments needed for post-Brexit compliance.
Regulatory divergence
UK and EU law are increasingly diverging — financial services, product standards, employment rights. We track changes in both regimes.
Customs & VAT
Goods moving between France and the UK now face customs declarations and different VAT treatment. We coordinate with your tax advisors.
Professional mobility
Sending employees between France and the UK now requires immigration advice, social security coordination, and potentially A1 certificates.
Equivalence gaps
Several EU-UK equivalence decisions remain unresolved (financial services, data). We advise on current compliance pathways.
Dual-jurisdiction commercial contracts
A contract that works under English law may not translate well into French. We draft contracts that are enforceable in both jurisdictions.
Choice of Law & Jurisdiction
We advise on the optimal governing law and dispute resolution forum — balancing enforceability across both countries.
Cross-Border Distribution
Distribution agreements that comply with both English and French competition law, including agency protections.
Bilingual Contracts
Fully bilingual agreements where both language versions are binding — avoiding interpretation disputes.
Cross-border employment scenarios we handle
- UK employee posted to France — social security coordination, A1 certificate
- French employee working remotely from the UK
- Secondment agreements between UK parent and French subsidiary
- Managing performance or termination across both legal regimes
- Creating harmonised employment policies for a dual-country team
Employment law across two jurisdictions
Managing employees in both France and the UK means navigating two distinct legal frameworks: French CDI/CDD contracts and collective agreements on one side, UK employment contracts and statutory rights on the other.
We advise on both, ensuring consistent people practices while respecting the mandatory rules in each country — no costly surprises during audits or disputes.
UK–EU data transfers post-Brexit
The EU-UK adequacy decision (adopted June 2021) currently allows personal data to flow from the EU to the UK. We monitor its status and ensure your transfer mechanisms are compliant.
Adequacy Assessment
Reviewing your data flows to ensure they rely on valid transfer mechanisms under both UK GDPR and EU GDPR.
Standard Contractual Clauses
Implementing the correct SCCs (EU or UK IDTA) for transfers not covered by adequacy decisions.
Binding Corporate Rules
For larger groups with extensive intra-group data sharing — we advise on whether BCRs are appropriate.
Operating across France and the UK?
One bilingual team. Two jurisdictions. No translation layer. Book a free discovery call to discuss your cross-border legal needs.
Book a free call