Das auf internationale Gerichtsstands- und Schiedsvereinbarungen anwendbare Recht

The present work deals with the determination of the law applicable to international choice of court and arbitration agreements pursuant to Art. 25 Brussels I Regulation and the provisions of the New York UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards of June 10, 1958. First, the law applicable to international choice of court agreements and then the law applicable to international arbitration agreements are identified in order to work out existing similarities and differences. Subsequently, specific proposals for amendments de lege ferenda are made for difficulties that have been identified de lege lata.