Notwithstanding the recent trend observed in comparative law towards the enactment of monist arbitration laws (which provide the same rules for domestic and international arbitration proceedings), France has remained faithful to its dualist tradition. The new French decree on arbitration of 13 January 2011 makes a clear distinction between domestic and international arbitration. If some of the preexisting differences between the two regimes are expunged, others are maintained while new differences are added by the adoption of (even) more liberal provisions in international arbitration. In fact, French dualism goes beyond these differences as it is rooted in the very conception of international arbitration itself, as completely delocalized.
Iurgium [previously Spain Arbitration Review]