Symeon Symeonides, ‘The Scope and Limits of Party Autonomy in International Contracts: A Comparative Analysis’

ABSTRACT
Party autonomy, ie, the notion that parties to a multistate contract should be allowed, within certain parameters and limitations, to agree in advance on which state’s law will govern their contract is now a universal principle – it is accepted in at least 150 countries. However, this virtual unanimity at the level of general principle comes with significant variations in the specifics. Party autonomy is neither conceived nor implemented in the same way in most countries. The most significant differences involve the scope of this principle and the limitations to which it is subject …

Symeonides, Symeon, The Scope and Limits of Party Autonomy in International Contracts: A Comparative Analysis (March 25, 2019). Franco Ferrari and Diego P Fernández Arroyo (eds), The Continuing Relevance of Private International Law and New Challenges (forthcoming 2019).

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