Abstract

Despite the abundant number of scholarly writings about non-signatories in international arbitration, few of them deal specifically with the question of the applicable law. Probably due to the international context of the disputes, the relation between the theories about non-signatories and the different national laws has often been overlooked. Are national laws relevant to decide on the extension of the arbitration agreement? And if so, which law should apply? This article attempts to answer these questions, describing some of the main theories about non-signatories and analyzing from a ...