PROBLEMS OF CHOICE OF LAW IN INTERNATIONAL COMMERCIAL ARBITRATION

Abstract

It is arguable whether applying a specific state's legislation or the model rules
used in the world of international trade is more effective in settling a dispute in
international commercial arbitration. The article examines the issues of selecting the
law that applies to disputes in international commercial arbitration, determining the
law that will be applied governing the dispute if the parties do not specify this issue,
interpreting and incorporating the law that the parties selected, and the use of
imperative norms. To conduct this analysis, transnational law, the rules of international
institutional arbitration courts and cases from the practice of international commercial
arbitration were used, and as a result of the analysis, work was carried out to determine
the best of them.