Current perspectives on Singapore jurisdiction governing law in cross border transactions in Asia
10 October 2022
Singapore has seen exponential growth and a rise in the comparative standing as the preferred dispute resolution centre in Asia. This has taken place in parallel with the rise of cross-border business transactions in Asia.
In this article, Partner Dawn Tan along with Tony Grundy discusses this trend and explores the considerations which influence the choice of Singapore as the preferred dispute resolution centre, in particular, as preferred arbitration venue, from the perspective of transaction (M&A, banking, and project finance) counsel from international firms based in Singapore.
The article explores the following:
- Introduction
- Increased popularity of the SIMC, SIAC and SICC
A. Singapore International Mediation Centre
B. Singapore International Arbitration Centre
C. Singapore International Commercial Court - Factors influencing choice of Singapore as dispute resolution venue and Singapore law as governing law
A. Is choice of forum and governing (substantive) law driven by transaction counsel?
B. Choice of forum versus choice of governing law
C. Empirical observations based on recent cross-border transactions - Concluding remarks
The full article published in the SAL Practitioner Journal is available to download below.
The article was first published in the SAL Practitioner and is republished with permission from the Singapore Academy of Law.
