Abstract
[Autom. eng. transl.] This contribution comments on the June 19, 2014 decision of the Singapore High Court in the case of FirstLink Investments Corp Ltd v GT Payment Pte Ltd and others concerning the law applicable to the arbitration clause in the absence of choice of parties. In particular, the High Court approach is discussed according to which unless otherwise specified, it is normally considered that the parties have implicitly chosen the law of the registered office as the law applicable to the arbitration agreement and, on equal terms, the mere identification of a The law applicable to the main contract is not in itself sufficient to overcome the presumption that the parties have considered the law of the venue as the law applicable to the arbitration agreement.
Translated title of the contribution | [Autom. eng. transl.] Determination of the law applicable to the arbitration agreement in the absence of express choice of the parties |
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Original language | Italian |
Pages (from-to) | 833-852 |
Number of pages | 20 |
Journal | RIVISTA DELL'ARBITRATO |
Publication status | Published - 2015 |
Externally published | Yes |
Keywords
- arbitrato internazionale
- clausola arbitrale
- legge applicabile