England is arguably the greatest global exporter of legal services and the rest of the world does not seem to like it.

From Spain to Japan, the Czech Republic to India, local professions have resisted the arrival of the English legal profession, fearing a loss of work and the recruitment of their best local lawyers.The World Trade Organisation (WTO) may offer a solution.

Its investigation into the world-wide provision of professional services is likely to give lawyers a right of establishment under home title in any of the countries -- currently more than 120 -- signed up to the General Agreement on Trade in Services (GATS).The WTO's working party on professional services has begun by investigating obstacles to free trade within the accountants' profession.

By the end of 1997, it hopes to produce: binding standards for professional qualifications in each country; guidelines on what should be included in cross-border agreements that recognise mutual qualifications; and recommendations for international accounting standards.Some fear that these changes will make the accountancy profession truly international and give it a head start in competing with law firms.

Mario Kakabadze, secretary to the working party, denies that this will happen.

Accountants are being investigated first but this does not mean rules specific to them will be issued, Mr Kakabadze points out, saying: 'We won't rush into a rule-making exercise.'Indeed, the working party does not have a deadline by which to finish its work on the professions, although Mr Kakabadze says many countries would like some rules in place for the next round of liberalisation negotiations, due at the end of the century.

He adds that whatever does eventually emerge from the WTO will be enforced.

'There will be some binding rules, obliging members to take action,' he says.Mr Kakabadze also scotches widely expressed concerns -- like those of the IBA's immediate past president, Ross Harper (see [1996] Gazette, 14 August, 1) -- that whatever structure is determined for accountants will be imposed on lawyers and the other professions.

As Jonathan Goldsmith, the Law Society's head of international, says: 'We would not like a template put on us willy-nilly.' Mr Kakabadze responds: 'There is a strong feeling that the professions all have different identities and that they should not be put into one pot.'The European Union represents all member states before the WTO and an official in its professional services unit speculates that the WTO will not have time to look at the professions one by one.

However, he said that there was no question of saving time by imposing the model for accountants.

His view is that the two extremes would meet half way.

The key would be recognising certain common elements to all professions, he says, which would speed up the process.So it is not clear when lawyers will be dealt with.

Together with architects, they are seen as the next most important profession to be investigated.

Mr Kakabadze says member countries are open-minded about how to handle these other professions.

It could happen after the investigation into accountancy services is completed or work could start du ring next year.

A decision will be made in 1997, once the progress on accountants is assessed.

However, the first assessment will come early next month, when the world's trade ministers meet in Singapore.

Mr Kakabadze predicts that nothing concrete on lawyers will emerge then.The WTO's work is largely supported by the Law Society, which -- with some justification -- describes its regime for foreign lawyers as possibly the most liberal around.

'It is in our interests as English solicitors to ensure that we can practise under home title in as many countries as possible,' says Mr Goldsmith.But there are concerns that a row at the Council of Bars and Law Societies of Europe (CCBE) -- officially recognised by the EU as the voice of Europe's 450,000 lawyers -- could have some impact on the EU's line to the working party.

The argument that split Europe's legal profession over the European Rights of Establishment Directive -- and was repeated earlier this year over the IBA's foreign legal practitioner regime -- is having yet another airing over the WTO's investigation.

A vocal minority within Europe, led by the French, would prefer all foreign lawyers to integrate with the host state's profession.However, global liberalisation of the legal profession is now a real, if not yet immediate, prospect.

Mr Kakabadze says that the accountants had been very organised in telling the WTO what they wanted and that lawyers have to do the same.

The IBA has taken the lead in this, and recently sent a delegation of 18 lawyers to Geneva to meet the working party.

Ward Bower, an American lawyer who heads an IBA committee investigating multidisciplinary partnerships, was one of them.

He says more immediate developments, such as MDPs, could render the WTO's contribution as 'too little, too late'.Nevertheless, the IBA is trying to influence the debate in more practical terms.

It decided last month to continue with plans to lay down model, non-binding guidelines giving foreign lawyers rights of establishment under home title and hopes to finalise these by the summer of 1997.

Mr Kakabadze offers some encouragement.

'Anything that aids the liberalisation process would potentially be of interest,' he says.Mr Kakabadze concludes: 'My message to the legal profession is that you should understand what's at stake, work out your position and then sell it to your respective governments.'