الهيئة الدولية للتحكيم
In what order are choices made
about governing law, seat and
institution/rules and do the
choices influence one another?
appropriate for the contract; a contracting party
from a very different legal system will typically
engage in a discussion as to which law is
appropriate to govern the contract and often a
neutral, well-established law will be preferred.
Almost invariably, interviewees indicated that
they would be most happy first with their own
law and secondly with well-established and
well-known laws, such as English, New York
and Swiss law. These issues are discussed
further in Section 2.
الهيئة الدولية للتحكيم