Is there any major consideration to take into account when selecting the seat of arbitration?

Yes. The key word is: anticipate. It is essential to give the contracting parties the security of a legal system that will ensure the enforceability of their award, avoiding expensive litigation about their arbitration while nevertheless ensuring that effective recourse is available in the event of procedural difficulties or irregularities. The principle under French law is that annulment of an award is possible only for specific and serious problems. French court procedures allow these actions to be heard quickly and inexpensively. On the contrary, in some other seats, it is possible to appeal arbitral awards on points of law, and annulment actions can be drawn-out and expensive affairs.


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