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Parties face a number of choices in arbitration: governing law, seat, choice of institution and likely constitution of the tribunal. These decisions ultimately determine the procedural process and conduct of any future arbitration. We have compared how arbitration users around the world have made those choices in international commercial disputes currently before major arbitral institutions – the ICC, LCIA, SIAC, HKIAC and the ICDR. Countries and nationalities have been colour-coded in the charts below for ease of comparison.
The contents of this publication are for reference purposes only and may not be current as at the date of accessing this publication. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action based on this publication.
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