Liquidated Damages

В статье рассматривается институт заранее оцененных убытков в законодательстве зарубежных стран. Заранее оцененные убытки призваны разумно и справедливо согласовать интересы сторон и не должны рассматриваться в качестве ответственности правонарушителя. Заранее оцененные убытки отличаются от штрафных убытков, то есть штрафных санкций. В суде соглашение о заранее оцененных убытках может быть реализовано при наличии следующих условий:

– стороны подписали контракт, при нарушении которого потенциальные убытки  труднодоказуемы;

– потенциальные убытки являются компенсацией, но не имеют характера штрафа.

Таким образом, заранее согласованные убытки не препятствуют потерпевшей ущерб стороне добиваться компенсации дополнительных убытков, то есть взыскания штрафных санкций, предусмотренных контрактом.

Оговорка о заранее оцененных убытках в контракте означает только  то, что заранее определен размер убытка, но не сторона, которая за него отвечает.

Значительное внимание уделяется автором зарубежной практике. Автор отмечает преимущества заблаговременного определения размера убытков. Автор приходит к заключению об отсутствии в украинском законодательстве правового института заранее согласованных убытков.

Foreign economic activi­ty is a very risky sphere of operational acti­vity of huge enterpris­es. Thus, harmonized cooperation on the part of all its participants will lead to successful completion of projects and receipt of profit for company as well.

However, taking into account the possible risks, which parties can encounter, it is important to predict and evaluate any eventual losses, caused by intentional or accidental behavior of the parties. In such situations lawyers usually use the definition of “guilty party”, but it is obviously known that in some cases it is extremely difficult to prove the fault, which could cause never-finished debates, re­alized in future disputes between parties. Thus, parties to a contract use liquidated damages where ac­tual damages, though real, are dif­ficult or impossible to prove.

The aim of this article is to analyze the legislation of foreign countries, which managed to cre­ate the appropriate mechanism of satisfaction of parties’ demands in cases, mutually agreed in the relevant document.

Subject matter

In many foreign countries, contracts that involve the ex­change of money or the promise of performance have a liquidated damages clause. The purpose of this stipulation is to establish a predetermined amount that must be paid if a party fails to perform as promised.

For example, liquidated dam­ages clauses are commonly used in real estate contracts. A builder who does not meet a schedule of project execution, may have to compensate this delay. Liqui­dated damages are an amount, estimated at equal the extent of injury that may occur, if the con­tract is breached. These damages are determined when a contract is drawn up and serve as protection for both parties that have con­cluded the contract, whether they are a buyer and a seller, customer and exécuter, an employer and an employee or other similar parties.

Analyzing the foreign prac­tice, it should be noted that liqui­dated damages clauses possess sev­eral contractual advantages:

1.  The parties can establish some predictability involving costs, so that parties can balance the cost of anticipated perform­ance against the cost of a breach. In this way liquidated damages serve as a source of limited insur­ance for both parties.

2.  Each party has the oppor­tunity to settle the dispute in an amount that is mutually agreea­ble, rather than leaving that deci­sion up to the courts and adding the costs of time and legal fees.

All parties agree that the amount of liquidated damages is fair and reasonable and would not act as a penalty to the breach­ing party.

Risks and their elimination

Liquidated damages are not imposed, if the defendant can show that the liquidated dam­ages clause was included as pu­nishment for failing to keep con­tract terms, instead of covering improvable damages, i.e. punitive damages. Let’s do the research!

The court system will enforce a liquidated damage clause if it meets two conditions:

a) When both parties sign a contract the potential damages are uncertain and difficult to prove and

b) The damages have to be a compensation for injuries and not referred to as a penalty, namely the court systems will not en­force a penalty clause in a con­tract (England, Germany, etc). The liquidated damages are rea­sonably proportionate to the expected probable loss from a breach. Otherwise, where the liq­uidated damages are dispropor­tionately high to the anticipated loss, the provision will be deemed to be an unenforceable penalty.

Summing up, there are three criteria distinguish valid liqui­dated damages provisions from invalid penalty provisions:

1.  The parties must intent to provide for damages rather than for penalty,

2.  The injury must be “uncer­tain” or “difficult to quantify” and

3.   The stipulated amount must be a “reasonable pre-estimate of probable losses”.

It is worth mentioning that liquidated damages do not pre­clude the injured party from seeking additional damages as provided within the contract.

Enforce the law

Along the same lines, the inclusion of a liquidated dam­ages clause may be considered as a form of insurance from the breaching party to the innocent party. This would occur when one party places a high subjec­tive value on performance of the contract and the other party is best able to provide the insur­ance necessary to compensate for harm to the subjective value.

Release of funds to the seller or executer in the event of a buyer’s or customer default is not automatic. It requires mutual consent and a separate signed re­lease. If the deposit is increased, both parties are required to sign a separate liquidated damages form to cover the increased deposit.

Remember too that the liq­uidated damage provision de­termines the amount of dam­ages the seller will receive, but is does not mean that release of the funds will be automatic. The escrow holder is a neutral third party and can only act with the consent of both parties to / the escrow. That is why I stated above that by signing the liqui­dated damages clause the parties “in theory” ensure certainty and avoid the fight. A dispute over which party breached the RPA-CA may still result a legal dis­pute to determine who breached. The liquidated damages provision only determines the amount of the damages. It is the rest of the RPA-CA’s provisions that deter­mine which party is in breach.

Foreign experience

American experience

The American approach to liquidated damages can be il­lustrated by both the Uniform Commercial Code and the Re­statement 2d Contracts: Restate­ment 2d Contracts Para. 356: Damages for breach by either party may be liquidated in the agreement but only at an amount that is reasonable in the light of the anticipated or actual loss caused by the breach and the difficulties in proof of loss. A term fixing unreason­ably large liquidated damages is unenforceable on grounds of public policy as a penalty.

Common law countries

Most common law countries such as England, Australia, Ire­land and Canada have similar rules with regard to liquidated damages, and do not allow for liquidated damages that are used as a penalty. One exception to the rule is India, where the Con­tracts Act makes no distinction between liquidated damages and penalties and allows for contrac­tual damages for failure to per­form even if the intention is to penalize.

Civil law countries or Eu­ropean experience

In civil law countries, the at­titude toward contractual penal­ties is quite different from the common law approach. The Na­poleonic Code, upon which most civil codes are based, allowed for penalties to encourage perform­ance of contractual obligations.

The Council of Europe issued a Resolution on Penalty Clauses in 1971 with the aim of recom­mending a uniform application of penalty clauses for the mem­ber states to use. The resolution allows penalty clauses, but the penalty amount may be reduced by the courts if they are mani­festly excessive or if part of the main contractual obligation of the contract has been performed.

It is difficult to find any uni­form application of liquidated damages/penalty clauses in case law of the various European countries. In most countries, the courts never evaluate the intent behind the penalty. Whether it is enforceable depends solely on whether it is excessive in its amount. Some countries have, however, taken a more restric­tive approach, and also examine the relationship between the penalty/liquidated damages and the actual loss, suffered by the plaintiff. This approach is simi­lar to the common law approach to liquidated damages.

Worldwide

The exception is in the UNICITRAL uniform rules relat­ing to liquidated damages and penalty clauses; this problem has been solved by simply referring to both as “contract clauses for an agreed sum due upon failure of performance. According to the UNICITRAL rules, an agreement between parties of a contract to pay a certain sum in the event of non-performance is generally allowed, whether as a penalty or compensation. However, the amount can be reduced by the courts if it is substantially dis­proportionate to the actual loss.

Advantages of liquidated damages

Taking into account the aforementioned, advantages of liquidated damages are the fol­lowing:

  1. Proof of damages is often an exceedingly complex and time-consuming process which would be removed from issues at trial. This would save time and money for the courts as well as parties in both pre-trial preparation and courtroom time. In general, the trial would be more efficient be­cause the number of issues before the court would be reduced.
  2. The theory of compensa­tion damages instead of punitive damages is applied.
  3. The general rule is that a court cannot increase or de­crease the amount of liquidated damages. However, it should be noted that could be restricted by law. For example, for resi­dential purchases of one to four units, California law sets the maximum amount of liquidated damages at 31% of the purchase price.

4. The determination in advance of the amount of compensation for damages (liquidated damages) shall not prejudice an obligor’s right to demand performance or rescis­sion.

Conclusion

And to conclude, it is impor­tant to take into account and written in the document, con­cluded  between  counterparts from different countries, the liq­uidated damages clause when the document is governed by the law of European or American countries. If you decide to use for regulation of documents a law of Ukraine, it should include the penalty clauses provided by the Civil Code and Commercial Code of Ukraine. Currently not included in the legislation, the concept of liquidated damages is a possible way to ensure the counterpart to accept to con­ceive the included penalties as liquidated damages rather than punishment. I think that the modification of Ukrainian legis­lation with regard to inclusion of liquidated damages provision is the next step in legislation development and reducing the workload of courts.

It is DIFFICULT to FIND any UNIFORM APPLICATION of LIQUIDATED DAMAGES/ penalty clauses in CASE LAW of the EUROPEAN COUNTRIES

LIQUIDATED DAMAGES AND PENALTY CLAUSES IN FOREIGN COUNTRIES

COUNTRY                                                             RULE OF LAW

EUROPEAN APPROACH TO LIQUIDATED DAMAGES:

France Articles 1226 to 1233 of La Code Civil regulates “la clause                          pénale” (penalty clause), and Article 1152 regulates                                      “dommages-lnterest” (liquidated damages). The former may be                reduced by a judge if part of the main contract obligation has                  been performed and if it is “manifestly excessive”. Liquidated                    damages may also be adjusted If “obviously excessive or                            ridiculously low”.

Italy     Both concepts, “clausola pénale” (penalty clause) and                                    “liquidazione convenzionale del danno” (liquidated damages),                  exist in doctrine, but not in the Civil Code. Penalties are                              generally enforceable but can be mitigated if “manifestly                            excessive” or if part of the main contract obligation has been                    performed.

Spain    Article 1154 of the Codigo Civil regulates penalty clauses                            (Clausula Penal), which can be reduced by a judge if part of the                main contract obligation has been performed. There Is no                          provision regarding mitigation of the penalty because of                            excessiveness, which makes Spain one of the few countries                        that has not amended its Civil Code to allow a reduction in the                  amount of the penalty.

Gemany There is a distinction between liquidated                                                              damages(Schadenspauschale) and contractual                                                penalties(Vertragsstrafe) in the German Civil Code, and both                      are allowed In accordance with Article 340 and 341 of the                        BGB. The difference between them Is that the latter can be                          mitigated if “disproportionate or excessively high”.

Netherlands/

Switzerland  Both of these countries have rules similar to Germany,                                 except that a penalty may be mitigated in the                                                   Netherlands If “manifestly excessive” and In Switzerland                              if “excessive”.

Belgium  Penalty clauses are permitted, but the amount can be                                  mitigated if it “obviously exceeds the actual damage” and if                        part of the main contract obligation has been performed.

Scandinavia The laws of Denmark, Finland, Norway and Sweden allow                           either the voiding or reformation of a penalty clause that                           is deemed to be “unreasonable”. Swedish law specifically                             provides for an evaluation of the relative bargaining                                     power of the parties In making this determination. The                               Swedish Commercial Code Section 36 (2) provides that                               “particular consideration” shall be given to protecting the                           party “in a subordinate position in the contractual                                         relationship”.

OTHER CIVIL LAW COUNTRIES OUTSIDE EUROPE HAVE ADOPTED A SIMILAR APPROACH, SUCH AS:

China  Penalty clauses in contracts are permitted, according to                             Article 114 of the Chinese Contract Law. The amount can be                     increased or reduced by the People’s Court or in arbitration if                 “excessively higher than loss”.

Russia  The New Civil Code from 1994 allows for both liquidated                            damages and contractual penalties in contracts. Both can be                    reduced by the court if obviously disproportionate to the                          actual loss.

Such changes came into force from 2013, namely: from 1 Jury                2013 the changes in Civil Code of Russian Federation came                        into force and supplemented by Article 1064 of the norm of                      the following content: “law or agreement can set up the                                obligation for the party that caused the damage to pay an                          injured person compensation above the reimburse of damage.                The Law can set up the obligation of a person who did not                         cause the damage to pay to injured persons compensation                         above the reimbursement of damage”. In this connection,                         legislators introduced amendments in the Town Planning Code               of the Russian Federation which came into force from 1 July                     2013. Thus, Article 60 has the following content: “In case of                     causing damage to a person or property of person, property of               citizen, property of legal entity because of destroy, damage of                 building, construction or part of building or construction,                         violation of requirements to the provision of safe exploitation                 of building, construction, the owner of such building,                                   construction (excluding case, provided by the article 2 of this                 article), if he does not prove that the indicated destruction,                       violation were caused because of the intention of an injured                     person, action of third parties or extraordinary or unavoidable               under such conditions circumstances of force majeure                                 reimburse the damage in accordance with civil legislation and                 pays compensation above the limits of reimburse of damage                     to:

1)  relatives of injured party (parents, children, adoptive                           parents, adoptees), husband / wife in case of death injured                         party — in the amount of three million rubles;

2)  injured party in case of cause of hard damage to this / her                   health — in the amount of RUB 2 million rubles;

3)  injured party in case of cause of average value damage to his               / her health — in the amount of RUB one million.

The deals about non-typical losses are actions of subjects of                      civil law, directed to the settlement, change or finish of civil                      laws and obligations, which lead to the transformation of lawful              finish or limitation of right of subjects of civil turnover in                          monetary equivalent, which comply with their sum of                                  compensation.

The most important thing in this case is the compensation                          amount for refusal from the ownership right or limitation of                      right (by agreement) of the subject of civil turnover.

In such a case, the case is about payment by the subject of civil               law of an monetary amount which is the first
obligation of subject of civil law on payment of compensation                 amount in account of reduction of any material
or other welfare of a person and is not an additional                                       encumbrance for him. Therefore, it is a special form of
monetary debt, because the payment is the essence of a                             primary obligation of the subject.
Therefore, it is necessary to draw the                                                                   conclusion:                                                                                               ”

1.    Liquidated damages can be:

—  set up in law,

—  agreed by parties in the agreement.

2.  Regulated in the agreement and sizes of losses should not be               considered as penalties, because they are just losses. Because it             is not possible to apply to them norms about the penalty,                           namely Article 333 of Civil Code of Russian Federation about a               decrease in the size of the penalty.

3.  Agreement about penalties in many cases releases the party               from a difficult process of proof of all conditions for the                               occurrence of loss.

EXAMPLES OF A MORE ANGLO-AMERICAN APPROACH:

Denmark The Supreme Court struck out penalty clause because of a                        disproportionate penalty in relation to the contract price.                        The penalty in question was four to six times the contract                          price. The court also found that the plaintiff had not proved                      that he had actually suffered the corresponding loss.

Belgium  The Court established that the amount in a penalty clause                          can be declared unenforceable if the penalty amount                                    “obviously exceeds actual damage”. However, the clause                            would not be voided, but the amount would be reduced.

EXAMPLES OF A MORE TRADITIONAL CIVIL LAW APPROACH:

Spain   A penalty clause was found to be unenforceable, since there                      was no connection to the main contractual obligation. The                        court did not discuss whether the amount was excessive or                      not.

Italy     The Court found that a penalty clause can be reduced if                                manifestly excessive, or if the main contractual obligation has                been partially performed. Mitigation may be ordered by the                    judge even if neither of the parties has asked for it.

Portugal The Supreme Court upheld a penalty clause in a car lease                            contract, since the penalty was in proportion to the risk of a                      breach of the contract and loss of the value of the car.

Автор: Katerynа A. NASTECHKO

Источник: The Ukrainian Journal of Business Law. – December. – 2013. – P. 31 – 34.

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