RESOLUTION OF CORPORATE DISPUTES IN INTERNATIONAL COMMERCIAL ARBITRATION IN GERMANY AND UZBEKISTAN: A COMPARATIVE LEGAL ANALYSIS

Abstract

Germany has a reliable system of corporate dispute resolution. There is no division into international commercial arbitration and domestic arbitration in the country: the system is regulated by a single regulatory legal act – Book 10 of the German Code of Civil Procedure (Zivilprozessordnung, ZPO). The government of Uzbekistan is making significant efforts to expand the scope of international arbitration. In 2018, the Tashkent International Arbitration Institute (TIAC) ​​was established as Uzbekistan’s first international arbitration institution. The main goal is to facilitate the resolution of disputes between business entities in different countries, in particular those related to investments, intellectual property and blockchain technology, through international arbitration. In this study, we analyze these two jurisdictions by discussing the specific features of each and relevant advances in German experience. We support my analysis by studying the legal literature, legislation, legal commentaries and case law.