Choice of Law in International Commercial Contracts
«a product of a tremendous effort which is well-situated with the ongoing trend of harmonization of private international law rules. It is a major milestone towards a more predictable and efficient operation of international commerce.»
Sagi Peari, Senior Lecturer, Associate Professor, University of Western Australia Law School
Although the possibility of making a choice of law in respect of international commercial contracts has become widely accepted, national law still diverges in many respects with regard to the scope and relevance of, and the limitations on, party autonomy, leading to uncertainty in international commercial relations. Les mer
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Although the possibility of making a choice of law in respect of international commercial contracts has become widely accepted, national law still diverges in many respects with regard to the scope and relevance of, and the limitations on, party autonomy, leading to uncertainty in international commercial relations. This book compares the Hague Principles on Choice of Law in International Commercial Contracts (2015) with national, regional, supranational, and
international rules on choice of law around the world in order to chronicle the divergent approaches which exist today.
The work is introduced by a comprehensive comparative report which sets out the similarities and differences between the featured national, regional, supranational, and international rules, comparing such rules with those of the Hague Principles, thereby initiating a discussion on further harmonization in the field. Another report focuses on the application of the Hague Principles in the context of international commercial arbitration. Dedicated chapters analyse the Hague Principles from a
historical, theoretical, and international organizational point of view. Finally, examining each jurisdiction in detail, the book presents sixty national and regional article-by-article commentaries on the Hague Principles written by experts from all parts of the world. This dedicated and in-depth global
comparative study of national, regional, supranational, and international rules provides a definitive reference guide to the key principles in respect of choice of law for international commercial contracts.
international rules on choice of law around the world in order to chronicle the divergent approaches which exist today.
The work is introduced by a comprehensive comparative report which sets out the similarities and differences between the featured national, regional, supranational, and international rules, comparing such rules with those of the Hague Principles, thereby initiating a discussion on further harmonization in the field. Another report focuses on the application of the Hague Principles in the context of international commercial arbitration. Dedicated chapters analyse the Hague Principles from a
historical, theoretical, and international organizational point of view. Finally, examining each jurisdiction in detail, the book presents sixty national and regional article-by-article commentaries on the Hague Principles written by experts from all parts of the world. This dedicated and in-depth global
comparative study of national, regional, supranational, and international rules provides a definitive reference guide to the key principles in respect of choice of law for international commercial contracts.
Detaljer
- Forlag
- Oxford University Press
- Innbinding
- Innbundet
- Språk
- Engelsk
- ISBN
- 9780198840107
- Utgivelsesår
- 2021
- Format
- 25 x 18 cm
Anmeldelser
«a product of a tremendous effort which is well-situated with the ongoing trend of harmonization of private international law rules. It is a major milestone towards a more predictable and efficient operation of international commerce.»
Sagi Peari, Senior Lecturer, Associate Professor, University of Western Australia Law School
«Private and Public International Law practitioners as well as academics will find this Commentary of immense help as it offers extensive jurisdictional statements on the principles governing choice of law. The Commentary also presents a panoramic view of the comparative position of international instruments on choice of law and the cooperation between international organizations engaged in the articulation of choice of law rules.»
Ramani Garimella, Netherlands International Law Review
«The book is the bible on choice of law in international commercial contracts. It covers over 60 countries, including regional and supranational bodies' rules on choice of law.»
Chukwuma Okoli, Conflict of Laws