Alexander J. Bělohlávek, Univ. Professor, Dr.iur., Mgr., Dipl. Ing. oec/MB, Dr.h.c. Lawyer admitted and practising in Prague/CZE (Branch N.J./US), Senior Partner of the Law Offices Bělohlávek, Dept. of Law, Faculty of Economics, Ostrava, CZE, Dept. of Int. and European Law, Faculty of Law, Masaryk University, Brno, CZE (visiting), Chairman of the Commission on Arbitration ICC National Committee CZE, Arbitrator in Prague, Vienna, Kiev etc. Member of ASA, DIS, Austrian Arb. Association. The President of the WJA – the World Jurist Association, Washington D.C./USA.
36.I. INTERNATIONAL DIMENSION IN AN ARBITRATION AGREEMENT AND DIFFERENTIATION OF APPLICABLE LAWS IN ARBITRATION 36.I.1. Manifestations of the international dimension in arbitration Both Czech law and the prevailing practice abroad distinguish between domestic arbitration and arbitration in international matters (in matters with an international dimension) which usually (though not exclusively) involve proceedings in which the parties’ residence, habitual residence, seat / registered office, or place of business are located in the territories of different states. The result of such proceedings is an international arbitral award (unless the proceedings are terminated). In this connection, it is interesting to study the approach adopted by France, where Article 1504 of the NCPC [FRA] defines the international arbitral award as an arbitral award touching upon matters of international trade.