Introduction

The rules of the SCC and the CIETAC are similar in many ways. Both rules respect party autonomy, and are flexible to be modified by agreement between the parties. Under both sets of rules, the arbitral tribunal may conduct the arbitration in a manner as it considers appropriate (SCC Article 19 and CIETAC Article 29). The structure and the wording of both sets of rules are also similar. Both rules reflect to a certain extent the law of the country where the respective institution has its seat although this is truer for the CIETAC Rules than the SCC Rules. While the Swedish ...