The law applicable to the arbitration agreement: The Channel of division

England and Wales. Court of Appeal. Queen’s Bench Division. [2020] EWCA Civ 6 (Comm) – Case No: CL-2017-000792 – 20.01.2020 France. Cour d’Appel de Paris. Pôle 1 – Chambre 1 – Case No: 17/22943 – 23.06.2020

Résumé

If the United States and Great Britain were said to be two countries separated by the same language,[1] France and Great Britain now seem to be two countries separated, not only by the Channel, but by the same case.