Opting Out of the Domestic Arbitration Regime and Into the International Arbitration Regime, and Vice Versa: The Case of Switzerland
Introduction The lex arbitri of Switzerland is well-known for affording parties maximum autonomy and procedural flexibility. In line with these principles, parties to international arbitration proceedings have the possibility to opt out of the otherwise applicable Chapter 12 of the Swiss Private International Law Act (“PILA”) and to opt into the statutory rules governing Swiss-seated…