Das UNCITRAL Modellgesetz in der EU

»The UNCITRAL Model Law in the EU. Harmonization of the Law of Arbitration against the Background of Art. 1(2)(d) Brussels Ia-Regulation?«

The interface between arbitration and state court proceedings in the EU still allows the emergence of parallel proceedings. The dissertation analyzes this problem and proposes the enactment of a regulation based on the UNCITRAL Model Law as a solution. In addition to the competences of the EU in this area, the regulatory areas central to the problem are discussed in the context of the Model Law, followed by a comparative analysis of the application of the law in Ireland, Germany and France.