Generally speaking, each individual jurisdiction has adopted its own approach concerning the rules on the determination of the governing law applicable in proceedings in international matters. In the international practice, arbitral panels usually distinguish four relatively autonomous areas...

This paper deals with the question of the determination of the applicable law in international commercial arbitration. In particular, it focuses on the determination of the substantive law governing the legal relationship of the parties, as the law which needs to be distinguished from the law...

The applicable jurisdiction for insolvency proceedings, as provided by the Regulation (EC) No 1346/2000 on insolvency proceedings, is the court of the Member State where the debtor's centre of main interest (COMI) is located (Article 3(1)). The Regulation, however, does not provide a...

The article analyses the fundamental premises of the differentiation between substantive and procedural rules in private international law and arbitration. The author opens the paper with the general differentiation between substantive and procedural rules and the reasons for such...

International treaties therefore have priority over provisions of domestic origin (domestic lex arbitri). This mainly concerns two conventions, namely the New York Convention (1958) and the European Convention on International Commercial Arbitration (1961). In the field of international...