International Arbitration: The Seat is King. The Powers At the Seat of Arbitration, "There Must Be No Alsatia in England Where The King's Writ Does Not Run"

      Аннотация: The notion of "seat" or "Place" is one of the most disconcerting in the international arbitration system. It is usually confused with similar notions such as "Site", "Place", "City", "Venue", "Forum", "Home", "Territory" or "Jurisdiction". Legal professionals add to the complexity with Latin expressions referring to the same such as "Lex fori" (the law of the forum – the jurisdiction –the venue) or "Lex Loci" (the law of the place"). Beyond the nod to Thailand with the title "The Seat is King", this book is a tribute as well as a contribution to the knowledge and practice of international arbitration in the Kingdom of Thailand. Identifying the seat of arbitration, the home legal system is one of the most important features of an arbitration clause. It sets the framework for the law governing the arbitration procedure and more importantly, the process and rights relating to the enforcement of the arbitral award. The battle around the world for having the best or safest arbitration seat is real. What are the assets that a country can display to win such a beauty contest?

Ключевые слова: International Arbitration; Arbitration; Arbitration Agreement; The Seat; The Venue; The Place; The London Principles; Recognition and Enforcement, Arbitrage International, arbitrage, Convention d'arbitrage, siege, Place, Lieu, Les principes de Londres. Reconnaissance et execution