This article focuses on how to properly choose the applicable law in arbitrations for international commercial disputes in the Republic of Panama. The author explores the nuances and specificities when parties have expressly chosen an applicable law to the dispute, and the legal reasoning and theories behind properly selecting the law applicable to the merits when the choiceof-law by the parties is аbsent, considering different approaches such as conflictof-lаw rules, the closest connection test, the cumulative method, direct application of substantive law, international conventions and transnational principles of laws.
This article focuses on how to properly choose the applicable law in arbitrations for international commercial disputes in the Republic of Panama. The author explores the nuances and specificities when parties have expressly chosen an applicable law to the dispute, and the legal reasoning and theories behind properly selecting the law applicable to the merits when the choiceof-law by the parties is аbsent, considering different approaches such as conflictof-lаw rules, the closest connection test, the cumulative method, direct application of substantive law, international conventions and transnational principles of laws.