International Conflicts of Jurisdiction: Divergences on Resolution between the Common Law System and the Civil Law

This paper addresses the international conflicts of jurisdictions and the cases in which they may arise, in order to identify the existing contrasts on their resolution in the legal tradition of common law and civil law. Thus, when dealing with matters of private interest, legal systems are torn between the application of the forum non conveniens and the lis pendends. On the other hand, in matters involving public interests, the sovereign interest and existing state policies in adjudicating a case -whether due to stability or security issues- must be borne in mind the enforcement of law through extraterritoriality, as well as doctrine of the effects or the group economic unit doctrine.