This paper on the law applicable to arbitration agreements will start with an examination of the provisions adopted in international conventions on arbitration. The reason for this approach lies in the fact that, when national statutes contain choic of law rules specifically applicable to arbitration agreements, such rules tend to conform to those adopted by the conventions. However, problems of incompatibility between national choice of law provisions and the interpretation of international conventions may arise in the case of those countries which extend their general choice of law rules regarding contracts to rules concerning international arbitration agreements. Finally, this paper is intended to provide indications to arbitrators of solutions generally relied on in the international legal community. It does not merely seek to describe the way national courts have dealt with the law governing international arbitration agreements.
Lingua, Daniele, "The Law Governing Arbitration Agreements in International Trade" (1986). LLM Theses and Essays. 114.