Companies throughout Asia Pacific grapple with choice of law and choice of forum issues in every contract. The prevailing view in China is that a foreign company is best served to move arbitration off-shore in hopes of a more level playing ground than might be found under the traditional Chinese arbitration body, the China International Economic and Trade Arbitration Commission (CIETAC), or some of the newer PRC local arbitration commissions. The preferred venues for arbitration currently are Singapore and Hong Kong. Thus, it is important for companies to be aware of changes to the Singapore International Arbitration Commission (SIAC) Rules and how those changes might influence the decision on venue in drafting the next contractual dispute resolution provision.
