Choice of Law in International Commercial Contracts

This comprehensive guide explores choice of law principles in international contracts, comparing national and regional rules with the Hague Principles.

This global study serves as a definitive reference guide to the essential choice of law principles governing international contracts. It features 60 national and regional reports authored by experts from various parts of the world, along with a dedicated commentary on the Hague Principles as they apply to international commercial arbitration. The book highlights the widespread acceptance of party autonomy in choosing applicable law for international commercial contracts, while also addressing the significant divergences in national laws that create uncertainty in international commercial relations.

In Choice of Law in International Commercial Contracts, the authors compare the Hague Principles on Choice of Law (2015) with various national, regional, supranational, and international rules to document the diverse approaches currently in practice. A comprehensive comparative report introduces the work, outlining the similarities and differences among the featured rules and initiating discussions on potential harmonization efforts in this important area of law. Additionally, a focused report examines how the Hague Principles are applied within the context of international commercial arbitration.

The book delves into historical, theoretical, and organizational perspectives on the Hague Principles, offering detailed analysis of each jurisdiction. It culminates in an extensive collection of article-by-article commentaries on the Hague Principles, crafted by experts from around the globe. This thorough comparative study is an essential resource for understanding the key principles of choice of law in international commercial contracts.