This, of course, like everything else, will depend on whether the UK strikes a trade deal with the EU by 31 December 2020.
The current position is that any judgment issued by the English Court or, for example, the Italian Court shall be treated in Italy or in England as if it were a judgment of its own Courts. It is automatically recognised and immediately enforceable. This means that Italian or English commercial parties cannot avoid their obligations to parties from the other country by keeping their assets against which judgments can be enforced in their own country.
The Lugano Convention provides a comparable and relatively easy way for Judgments to be recognised and enforced. The UK is hoping to accede to this as part of an overall deal with the EU.
If the agreement between the parties over which the dispute arose is a commercial agreement containing an ‘exclusive jurisdiction clause’ then the Hague Convention on Choice of Court Agreements sets out a relatively easy process by which an English or Italian Judgment can be recognised and enforced. The UK has confirmed that it will accede to this on 1 January 2021.
If there is no Lugano Convention and the Hague Convention doesn’t apply, then the situation would be very different. Each country would have the right to follow its own internal rules on whether a Judgment is capable of recognition and enforcement. In England, in order to convert an Italian Judgment into one capable of enforcement in England, you would have to issue fresh proceedings, under what’s referred to in common law as ‘an action on a Judgment’. This would mean a delay of some months and extra costs incurred in converting the Italian Judgment into an English one or vice versa.