Mealey’s International Arbitration Report
Determining The Law Applicable To Arbitration Agreements: The Common Law Approach
International commercial arbitrations resolve disputes with international elements. Given the diversity of parties to international commercial transactions, the disparate disputes to which they give rise, and the practical inevitability of a seat in a jurisdiction which is foreign to at least one of the parties, it is far from surprising that more than one system of law is frequently relevant to the conduct of an international commercial arbitration.
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