TFL Vsebine / Revija Slovenska arbitražna praksa

When concluding cross-border contracts, parties should consider, among other things, which substantive law will govern the contract. If parties choose arbitration as their dispute resolution mechanism, the substantive governing law can also be agreed at the initiation of (or, more rarely, during,) the arbitral proceeding. In contracts or disputes concerning international sales of goods, the United Nations Commission on International Trade Law (UNCITRAL) has produced two legal texts which present themselves as particularly apt options for parties considering this question: the United Nations Convention on Contracts for the International Sale of Goods (CISG) and the Convention on the Limitation Period in the International Sale of Goods (Limitation Convention).