Does France have its own “idea” of what international arbitration means?

Yes. The concept of international arbitration varies from country to country. Under French law, article 1504 of the Civil Procedure Code provides that “arbitration is international if it implicates interests of international commerce”. As a result, and independently from any other criteria – such as the parties’ nationality, residence or corporate headquarters, the place of the arbitration, or the applicable law – French law will consider an arbitration to be international as long as it relates to an economic operation that involves the international movement of goods or services or involves an international payment.


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