COMPARATIVE ANALYSIS OF THE RULES REGARDING CHOICE OF LAW IN CONTRACTS PROVIDED IN PRIVATE INTERNATIONAL LAWS OF THE DPR KOREA, RUSSIA AND CHINA
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Abstract
In several regions of the DPR Korea, Russia and China, including the area surrounding the River Tuman involving Rason of the Democratic People’s Republic of Korea (DPR Korea), Vladivostok of Russia and Hunchun of China, civil and commercial exchange among legal or natural persons of these three countries are being conducted not infrequently, which increases its necessity day by day. The majority of such civil or commercial exchange is carried out on the basis of contracts between parties. However, performance of contracts is often accompanied by various sorts of disputes, which impedes regular transactions among countries. The resolution of contractual disputes depends on which country they are litigated in.
The present paper aims at contributing to further expanding cooperative relations among neighboring countries by giving a better understanding of the rules regarding choice of law in contracts provided in the national laws of these countries, so that legal and natural persons of the DPR Korea, Russia and China can carry out civil and commercial exchange in a more rational way. On the basis of outlining the process of development of legislations on choice of law in contracts of the DPR Korea, Russia and China, the paper analyzes provisions of private international law of each country related to laws applicable to contracts and clarified their common and distinguishing features.
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