Applicable law provisions in international commercial law conventions. A coordinated approach to predictability in international commercial law

      Аннотация: The development of international trade requires predictability and uniformity of the applicable legal framework. Such requirements can be satisfied by means of international uniform commercial law conventions, which try to set forth coherent and uniform bodies of substantial rules. A key role is also played by private international law, an instrument operating at a different level but often included in the uniform conventions themselves. This book focuses on the relationship between international uniform commercial law conventions and private international law to investigate how it has developed over the last decades, and suggests a new approach to international commercial transactions in terms of coordination rather than alternativeness of the two different instruments.

Ключевые слова: applicable law, Commercial Law, Conflict of Laws, private international law, uniform law