...growing. For example, as of August 2023, Central Asian states were parties to 214 BITs with countries such as the United States, China, France, Germany, Switzerland, the United Kingdom, and...
...to be an attractive form of dispute resolution. It is telling that neither England nor France – two of the most important centers for international arbitration – adopted the Model...
...is nonetheless enforceable in France, so long as it satisfies French standards for enforcing arbtral awards. The “Chromalloy approach,” so-called after the leading American case on the subject, is that...
...France, held that it had jurisdiction to hear the matter and rendered a final award in favour of the claimant in October 2013. In April 2016, the Paris Court of...
...Arbitration (France) from Kyrgyzstan. Natalia Alenkina is a member of the Scientific Advisory Council of the Supreme Court of the Kyrgyz Republic as well. † Hannepes holds an LL.B degree...
...a few years ago, the Court dealt with disputes “across the Rhine” between French and German litigants. Now it has branches in Germany, Italy, France, Turkey, Croatia, Spain, Belgium and...
...Italy, France, Spain, Germany, etc.) to problems related to the applicability of an arbitration clause, particularly in the context of multi-contract transactions. I. ARBITRATION CLAUSES AND THEIR RELATIVE EFFECTS: A...
...the use of inaccurate presumptions and rules. By comparison, approaches employing “transnational principles” such as that adopted in modern American federal practice, or in France, as with Gary Born’s advocacy...
...Indian Model BIT (2015). In more overt practice, Colombia has steadily employed joint interpretative statements over the past few years via the Colombia-France Joint Interpretative Statement (2014), the Colombia-Israel Joint...
...by the Federal Arbitration Act and the Uniform Arbitration Act of the United States. The legal regime of France stipulates an implied duty of confidentiality only in domestic arbitration and...
...with the following examples: Although in Switzerland, Italy, France and Sweden, privilege does not extend to in-house counsels, it does in the United States and the United Kingdom. With regard...
...judicial proceedings starting in the 1960s, perhaps influenced by its use in First World countries, with the United States leading the way. Once established, as Anatole France once wrote, it...
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