Arbitration clauses in international commercial contracts are often reused from existing contracts. By so doing, the parties choose to apply, for example, either ad hoc or institutional arbitration and the UNCITRAL, ICC, LCIA, SCC, Swiss or other arbitration rules without necessarily being aware of the consequences. Moreover, parties often assume that an arbitration clause has the effect of excluding any kind of interference from a court of law and of rendering any but the chosen law redundant. This book highlights the specific features of various forms of arbitration and enables lawyers to make informed choices when drafting arbitration clauses. Chapters explain the framework for arbitration, its relationship with national law, and the features of the main arbitration institutions in Europe. The book also highlights new trends in other parts of the world that may have repercussions on the theory of international arbitration.
Introduction; Part I. Arbitration Law's Significance for International Disputes: 1. International arbitration is not only international Giuditta Cordero-Moss; 2. International arbitration and domestic law Luca Radicati di Brozolo; Part II. Ad Hoc Arbitration: 3. Ad hoc arbitration v. institutional arbitration Carita Wallgren-Linholm; 4. The UNCITRAL arbitration rules and their use in ad hoc arbitration Corinne Montineri; Part III. Institutional Arbitration: Features of Selected Arbitration Institutions in Europe: 5. Arbitration in Austria: features of the International Arbitral Centre of the Austrian Federal Economic Chamber (VIAC) Werner Melis; 6. Arbitration in Denmark: features Georg Lett; 7. Arbitration in Germany: features of the German Institution of Arbitration Jens Bredow; 8. Arbitration in Italy: features of the Milan Chamber of Arbitration Stefano Azzali; 9. Arbitration under the rules of the International Chamber of Commerce Simon Greenberg and Anders Ryssdal; 10. Arbitration in London: features of the London Court of International Arbitration Johannes Koepp, Dorine Farah and Peter Webster; 11. Arbitration in Norway: features of the Oslo Chamber of Commerce Stephen Knudtzon; 12. Arbitration in Russia: features of the International Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation Alexander Komarov; 13. Arbitration in Sweden: features of the Stockholm rules Henrik Fieber and Eva Storskrubb; 14. Arbitration under the Swiss rules Daniel Wehrli and Marco Stacher; Part IV. New Trends in International Arbitration: 15. 'Domesticating' the New York convention: the impact of the U.S. federal arbitration act George Bermann; 16. New trends in international commercial arbitration in Latin America Diego Fernandez Arroyo.
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