Swiss Federal Tribunal applies Article 186 (1bis) of the Swiss Private International Law Act in a case involving parallel proceedings before two arbitral tribunals
Article 186 of the Swiss Private International Law Act (“PIL Act”) provides as follows: “1. The arbitral tribunal shall decide on its own jurisdiction. 1bis. It shall decide on its jurisdiction notwithstanding an action on the same matter between the same parties already pending before a state court or another arbitral tribunal, unless there are…