Suchergebnisse

The scope of this article is to identify the law governing the international commercial arbitration by reporting the international and internal regulations. We shall consider the situation of contracting parties selecting the law governing their contract and when the parties have not selected the governing law and decided for arbitration as manner of solving their disputes.

The United Kingdom voted to leave the European Union, ending a 40-year relationship. Britain's exit (Brexit) will no doubt affect European Union private international law, which is currently part of the United Kingdom's legal system. This article attempts to predict the sort of arbitration and private international law that the United Kingdom will have after its departure from the European Union. The article proposes that European Union private international law could be easily transposed into United Kingdom domestic law. In addition, the United Kingdom enforcement of court decisions in the European Union, after exiting the union and without concluding any further agreement with the union as to how jurisdiction must be allocated, should be achieved through the United Kingdom joining the Hague Convention on Choice of Court Agreements. Finally, the paper concludes that Brexit will increase the use of English law and the specification of England and Wales as the jurisdictions in international commercial contracts because the United Kingdom would no longer be required to incorporate those aspects of European law that can prove problematic.