Conflict of Laws Regulation of Labor Relations with Foreign Participation in the Labor Law of the EAEU States: Problems and Trends

Abstract

The study of the legal means of conflict of laws regulation contained in the labor codes of the states of the Eurasian Economic Union indicates their obvious insufficiency and incompleteness of the processes of adoption of conflict of laws norms of labor law intended to regulate labor relations complicated by a foreign element. The unilateral conflict of laws regulations contained in the labor codes of the states of the Eurasian Economic Union do not allow solving problems related to the regulation of labor relations complicated by a foreign element. This situation does not seem entirely justified and indicates a simplified view of labor relations with a foreign element, which still considers it possible to extend the principles and norms governing civil relations to the field of labor law. Taking into account the similarity of the systems of implementation of the norms of private international law based on civil codes in the states of the Eurasian Economic Union, it is concluded that it is advisable to adopt separate special chapters in the labor codes of these states providing for conflict of laws regulation of labor relations with foreign participation.