The harmonization of rules is an elementary concern of international commerce. In international business relations, the parties have a vital interest in reliably knowing their mutual rights and obligations. A contract does not necessarily settle all contentious issues and may give rise to controversies and lead to litigation. It may be a matter of doubt which law applies to the contractual relation, and the courts in different countries may reach different conclusions in this context. International agreements on the applicable law respond to this problem. Even...
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