Legal development

Current perspectives on Singapore jurisdiction governing law in cross border transactions in Asia

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    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:

    1. Introduction
    2. Increased popularity of the SIMC, SIAC and SICC
      A. Singapore International Mediation Centre
      B. Singapore International Arbitration Centre
      C. Singapore International Commercial Court
    3. 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
    4. 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.

    This is a joint publication from ADTLaw LLC (a Singapore law practice) and Ashurst LLP who together form Ashurst ADT Law, which is a Formal Law Alliance in Singapore.

    Ashurst LLP is licensed to operate as a foreign law practice in Singapore. Where advice on Singapore law is required, Ashurst LLP will refer the matter to and work with ADTLaw LLC or other licensed Singapore law practices where necessary.

    Ashurst LLP is part of the Ashurst Group which comprises Ashurst LLP, Ashurst Australia and their respective affiliates (including independent local partnerships, companies or other entities) which are authorised to use the name "Ashurst" or describe themselves as being affiliated with Ashurst. Some members of the Ashurst Group are limited liability entities. For more information about the Ashurst Group, which Ashurst Group entity operates in a particular country and the services offered, please visit

    This material is current as at 10 October 2022 but does not take into account any developments to the law after that date. It is not intended to be a comprehensive review of all developments in the law and in practice, or to cover all aspects of those referred to, and does not constitute legal advice. The information provided is general in nature, and does not take into account and is not intended to apply to any specific issues or circumstances. Readers should take independent legal advice. No part of this publication may be reproduced by any process without prior written permission from Ashurst. While we use reasonable skill and care in the preparation of this material, we accept no liability for use of and reliance upon it by any person.

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