Binding Rule Arising from the Extraterritorial Application of Competition Rules: Direct Effect on the Market (MÖHUK Art. 38)

Development summary

The article addresses the connecting rule that arises from the extraterritorial application of competition rules and the criterion of direct effect on the market.

It explains that, under PILA Article 38, private-law claims arising from competition infringements with a foreign element are governed by the law of the market directly affected.