Because there are so many options for the governing law, it is typical for an international contract to include a governing law clause
. Here is an example (for English law): English law governs this agreement.
If a contract's governing law is unclear, there are complex rules that determine which legal system should apply. These rules take into account the location of the parties, their obligations, and other circumstances. Complex rules lead to disputes like Apple Corps Ltd -v- Apple Computer Inc.
, where each party was overtly adamant that it did not wish to accept the other's jurisdiction or governing law.
Which law should you choose for your international contract? English and Swiss laws are the most popular choices, according to this 2014 paper
, which studied more than 4,400 international contracts: