THE COURTS IN QATAR FINANCIAL CENTRE AND DUBAI INTERNATIONAL FINANCIAL CENTRE: A COMPARATIVE ANALYSIS

Qatar and Dubai have established financial centres which are based on the common law jurisdiction of England and Wales because of the advantages such a system can give to the development of their respective financial services industries. The Qatar Financial Centre (QFC) and the Dubai Internatinal Financial Centre (DIFC) each have specialist courts, also based on English common law principles, to resolve civil and commercial disputes. These courts fall outside the framework which otherwise governs domestic courts in Qatar and Dubai. The benefits of the QFC and the DIFC set-up include familiarity to foreign investors, by being based on common law jurisdictions, laws and regulations which are written in English, as well as being overseen by both an independent judiciary and an independent regulatory body. The scope of this article is to compare the court systems of both the QFC and the DIFC, particularly the enforceability of the courts' judgments and the enforceability of the arbitration award, and to assess whether one financial centre is preferable over the other financial centre on the basis of the enforceability of court judgments and the enforcement of arbitral awards.