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Cross-border disputes

UK–China cross-border disputes: a practice hub for Chinese parties and Chinese-facing UK businesses

By Jackson Ng MCIArb · Partner & Barrister · 9 May 2026

For Chinese parties facing a dispute in the United Kingdom — and for UK businesses with Chinese counterparties, distributors, suppliers, investors or co-shareholders — Duan & Duan UK LLP runs a single integrated cross-border dispute resolution practice. This page is the firm's hub for that work, with guides covering each principal scenario. Jointly authored by Jackson Ng MCIArb (Partner & Barrister) and Leon Chua (Partner) of Duan & Duan UK LLP.

Why instruct an English law firm with a Chinese network?

The firm sits at the rare intersection that most cross-border instructions need. We are an English LLP authorised and regulated by the Solicitors Regulation Authority (SRA 659252), with all litigation conducted in the English courts under English procedural law. We share a brand and a working relationship with the wider Duan & Duan international network — over forty offices in mainland China, Hong Kong, Singapore and beyond — which is invaluable for the PRC-side evidence, witness coordination, and post-judgment enforcement that most UK–China matters require.

That structure means a Chinese client can run an English action without juggling two firms; a UK client can pursue a Chinese counterparty without relying on translated briefs and unfamiliar overseas advocacy.

Choose your scenario

Each guide below stands on its own — the headings are the questions our clients actually ask in initial consultations.

1. Enforcing a Chinese contract against a UK counterparty

→ Enforcing a Chinese contract in the UK: governing law, jurisdiction, arbitration, and the practical routes

Choice of route depends on the dispute-resolution clause: court litigation, arbitration with New York Convention enforcement of the award, or — where a PRC judgment already exists — a common-law action on the foreign judgment. Covers Rome I governing-law analysis (as retained in UK domestic law); the forum conveniens and exclusive-jurisdiction analysis for PRC and English jurisdiction clauses; the section 9 stay procedure under the Arbitration Act 1996 where there is an arbitration clause; and the enforcement procedure under sections 100 to 104 of the 1996 Act for New York Convention awards. Jackson Ng MCIArb (Partner & Barrister) and Leon Chua (Partner).

2. Suing a UK distributor or business from China

→ Suing a UK distributor or business from China: a cross-border jurisdiction and procedure guide

The English courts have general jurisdiction over UK-domiciled defendants as of right. A Chinese claimant can run the entire claim from China, with our office acting as the address for service. Covers service under section 1139 of the Companies Act 2006 on UK companies, the Hague Service Convention for individual defendants, conducting the proceedings remotely, interim relief (freezing orders, Norwich Pharmacal orders, search orders, springboard injunctions), and the strategic choice between English court litigation and arbitration where enforcement back into China is the likely endgame. Jackson Ng MCIArb (Partner & Barrister) and Leon Chua (Partner).

3. UK debt recovery against a Chinese supplier or distributor

→ The UK company didn't pay our invoice: a debt recovery guide for Chinese suppliers and exporters

Letter Before Action under the Pre-Action Protocol for Debt Claims; statutory demand and winding-up petition under section 123 of the Insolvency Act 1986 for undisputed debts; Part 7 claim with default judgment under CPR Part 12 or summary judgment under CPR Part 24; statutory interest at 8 percentage points above the Bank of England base rate plus the fixed administrative charge under the Late Payment of Commercial Debts (Interest) Act 1998; and the full English enforcement toolkit, from writ of control through third-party debt orders and charging orders to a follow-on winding-up petition. Leon Chua (Partner) and Jackson Ng MCIArb (Partner & Barrister).

4. Chinese shareholder disputes in UK private companies

→ Chinese shareholder dispute in London: a UK solicitor's guide for unfair prejudice and joint venture breakdowns

Section 994 of the Companies Act 2006 unfair-prejudice petitions in the Companies Court. Common patterns: exclusion from management in a quasi-partnership, diversion of opportunity to a connected party, non-payment of dividends in bad faith, and improper share issues. Remedies under section 996 — most often a buy-out at fair value, with no minority discount in quasi-partnership cases (Re Bird Precision Bellows Ltd [1986] Ch 658). Procedure under the Companies (Unfair Prejudice Applications) Proceedings Rules 2009 read with Practice Direction 49A. Jackson Ng MCIArb (Partner & Barrister) and Leon Chua (Partner).

5. Enforcing a Chinese court judgment in England and Wales

→ Enforcing Chinese Court Judgments in the United Kingdom: A Practical Guide

The common-law action on a foreign judgment, applied to PRC court judgments. The leading authority is Hangzhou Jiudang Asset Management Co Ltd & Anor v Kei [2022] EWHC 3265 (Comm), confirming that a final monetary PRC judgment can be enforced as a debt in the English courts on a CPR Part 24 summary-judgment application, subject to the four common-law conditions: competent jurisdiction in the English conflicts-of-laws sense, definite sum, finality, and absence of impeachment for fraud, breach of natural justice, or contrariety to English public policy. Jackson Ng MCIArb (Partner & Barrister).

Where the firm typically adds value

  • PRC-side coordination. We routinely co-instruct with PRC counsel to gather Chinese-side documents, interview Chinese witnesses, and secure PRC translations and notarisations that satisfy English evidential standards. PRC data-export and state-secrets considerations are part of the case-planning conversation from day one.
  • Bilingual advocacy and drafting. Pleadings, witness statements, skeleton arguments, and client correspondence in English; client conferences, settlement negotiations, and pre-action correspondence in Mandarin or Cantonese. Jackson is a barrister-partner with rights of audience in the Senior Courts of England and Wales; Leon leads commercial litigation in the Commercial Court and Chancery Division.
  • Forensic accounting and valuation evidence. UK–China shareholder disputes and contract-loss claims are frequently won or lost on the quality of the expert evidence on the underlying group structure. We work with specialist forensic accountants experienced in UK-listed and PRC-operating businesses.
  • Asset recovery and enforcement strategy. Pre-issue investigation of the defendant's UK and overseas assets, freezing orders on a worldwide basis where the threshold is met, and post-judgment enforcement through the full English toolkit. Where the assets sit only in mainland China, the choice between an English court judgment (case-by-case recognition by PRC courts following the Spar Shipping precedent in Shanghai Maritime Court 2022) and a New York Convention arbitral award (treaty enforcement in PRC courts) is the principal strategic question.

Recent matters

Duan & Duan UK LLP has acted in significant cross-border UK–China disputes, including:

  • Section 994 petitions concerning the UK restaurant operating companies in the Happy Lamb franchise group.
  • Commercial Court proceedings in HungryPanda AU Pty Ltd & Ors v Liu & Ors [2025] EWHC 1512 (Comm) — a £11.7 million damages judgment.
  • The Blue Sky Ge Rui (蓝天格锐) cryptocurrency victim compensation proceedings under the Proceeds of Crime Act 2002, representing Chinese victims of the £5.5 billion bitcoin Ponzi scheme.
  • Cross-border asset-recovery work for Chinese creditors of UK-based debtors and overseas judgment-debtors with UK-situated assets.

Practical first steps

  1. Preserve the documents. Email correspondence, WeChat / WhatsApp threads, signed contracts, purchase orders, delivery notes, invoices, payment records, board minutes. Where the documents are in Chinese, certified English translations can be commissioned as part of the matter.
  2. Take a limitation point early. English contract claims run six years from accrual; deeds run twelve years; tort claims run six years from damage. Pre-action protocol exchange does not stop time. Where PRC law is the governing law, the Foreign Limitation Periods Act 1984 treats foreign limitation as substantive — so the PRC limitation period applies under section 1, subject only to the narrow public-policy / undue-hardship exception under section 2.
  3. Map the corporate position. Companies House filings, articles of association, any shareholders' agreement, and the contractual chain — the proper claim cannot be pleaded without this map.
  4. Take advice before any unilateral move. A premature termination, a self-help asset freeze, or a public statement can itself become the conduct that founds the other side's claim.

Contact

For an initial confidential consultation in English, Mandarin or Cantonese:

Initial enquiries are without obligation and treated in strict confidence.

This hub page is general information only and does not constitute legal advice. Each cross-border matter must be assessed on its specific facts, including the contract terms, governing law, applicable limitation periods, and the parties' positions. Duan & Duan UK LLP is a limited liability partnership registered in England and Wales (OC427307), authorised and regulated by the Solicitors Regulation Authority (SRA number 659252).

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