International Arbitration Law Library »

The technical, economic, and social development of the last one hundred years has created a new type of long-term contract which one may call 'Complex International Contract'. Typical examples include complex civil engineering and constructions

1. Introduction: Complex international contracts and commercial arbitration
2. Legal characteristics of complex international contracts
3. The need to preserve complex international relationships
4. Determination of the applicable law through conflict rules
5. Exkurs: Applying art. 187 of the Swiss IPRG
6. 'voie directe': the 'direct method' of determining the applicable law
7. A national law (lex mercatoria)
8. Remedy against the arbitrators' choice of law?
9. The desire for contract adaptation
10. Contractual adaptation clauses
11. Exkurs: Renegotiation duty?
12. The power of arbitrators to adjust contracts
13. Substantive law on adaptation to changed circumstances in the absence of adaptation clauses
14. Facilitated adaptation of complex international contracts under a rule of lex mercatoria?
15. Multi-Party Arbitration
16. Fast track arbitration