Securing harmonized effects of international arbitration agreements. A comparative analysis of case law and legal doctrine in the United States, France, Italy and Switzerland

      Аннотация: There is little doubt that the arbitration agreement is the pillar of international arbitration. International commercial contracts include arbitration agreements which aim to protect the interest of the parties to resolve their disputes in a neutral and impartial venue. The ability of the parties to enforce their arbitration agreements under the New York Convention in a seamless way across various jurisdictions is hampered by diverging interpretations of domestic courts and legal commentators. This book aims to map the main interpretive trends by analysing the application of the New York Convention in various jurisdictions and to propose solutions that may assist in achieving a successful enforcement of arbitration agreements in a jurisdiction agnostic manner.

Ключевые слова: Arbitration agreement, commercial international comparative contracts