Recouvrement de dettes à l’étranger

time is money

Lorsqu’une personne située à l’étranger refuse de payer ce qu’elle doit, comment faire ?

La réponse suppose de prendre en compte plusieurs éléments. Tout d’abord, il convient de savoir si le débiteur est une entreprise d’un Etat membre de l’Union européenne ou non.

Si tel est le cas, il convient d’appliquer le Règlement communautaire n° 1215/2012 du 12 décembre 2012 pour déterminer la compétence internationale. Cela suppose de vérifier en premier lieu si une clause attributive de compétence a été insérée dans le contrat. Si oui, il faut en vérifier la validité conformément à l’article 25 du règlement. A défaut de clause ou de clause valable, le tribunal compétent est en principe celui de la résidence habituelle du défendeur, en l’espèce, le tribunal étranger. Mais d’autres règles de ce Règlement permettent d’assigner cette personne en France (en vertu notamment de son article 5).

Il convient de noter que le recouvrement de créances dans l’UE est devenu plus simple suite à l’adoption de plusieurs textes. Il s’agit du Règlement (CE) n° 1896/2006 du Parlement européen et du Conseil, du 12 décembre 2006, instituant une procédure européenne d’injonction de payer, du Règlement (CE) n° 805/2004 du Parlement européen et du Conseil, du 21 avril 2004, portant création d’un titre exécutoire européen pour les créances incontestées et du Règlement (CE) n° 861/2007 du Parlement européen et du Conseil, du 11 juillet 2007, instituant une procédure européenne de règlement des petits litiges.

Si l’entreprise débitrice n’est pas située dans un Etat membre, la société française pourra alors envisager de l’assigner en France en vertu notamment de l’article 14 du code civil qui institue un privilège de juridiction au profit des Français. Mais ce texte ne prévaudra que s’il n’existe pas de convention internationale conduisant à adopter une solution différente.

En toute hypothèse, une fois le jugement français obtenu, encore faudra-t-il le faire exécuter à l’étranger si le débiteur ne veut pas exécuter volontairement et n’a pas d’intérêts en France. Là encore le droit de l’Union européenne peut faciliter la tâche du créancier en admettant la reconnaissance automatique, voire le caractère exécutoire de la décision qui a été rendu, ce qui ne dispense pas de certaines démarches.

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