Niet alle wegen leiden naar Rome

A controversy has recently arisen in relation to the question whether the EU Rome I Regulation and its predecessor, the Rome Convention on the law applicable to contractual obligations, apply directly before arbitral tribunals seated in EU Member States, effectively preempting national arbitration rules containing provisions on the law applicable to the merits of disputes. This contribution discusses the relationship between these European instruments and national arbitration law, and concludes that the Rome I Regulation does not apply directly to contractual merits issues pending before arbitral tribunals having their place of arbitration in EU ... Verder lezen? Log in om dit document te bekijken.Verder lezen?