An award’s domicile is determined by the seat of arbitration and the governing law of the proceedings. However, in practice, confusion often arises regarding what actually influences this determination.
Therefore, it is equally important to consider the factors that do not affect an award’s domicile, as overlooking them can lead to misunderstandings, unfounded arguments, and even legally incorrect court decisions.
This article, by Partner Djordje Novčić and Senior Associate Ivana Petković, from JPM Belgrade office, explores both the determining and non-determining factors of an arbitral award’s domicile.