Generally speaking, when faced with the task of completing the UK end of a deal with an international flavour, most UK-appointed counsel will appreciate that significant differences exist between the law of England and Wales and that of Scotland. In order to deal with the Scottish aspects of the transaction, advice from Scots lawyers will often be required.
There is, perhaps not surprisingly, a general feeling that the law in Northern Ireland (NI) follows that of England and Wales. This is undoubtedly true – for years, NI law has emanated from Parliament at Westminster (albeit that much legislation is enacted by way of Order in Council rather than by Act) and it is undeniably the case that much NI legislation, particularly in the corporate and commercial sphere, substantially mirrors its English counterpart.
