{"id":36305,"date":"2008-03-26T16:35:41","date_gmt":"2008-03-26T21:35:41","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/uncategorized\/arbitration-international-commercial.html"},"modified":"2008-03-26T16:35:41","modified_gmt":"2008-03-26T21:35:41","slug":"arbitration-international-commercial","status":"publish","type":"corporate","link":"https:\/\/corporate.findlaw.com\/litigation-disputes\/arbitration-international-commercial.html","title":{"rendered":"Arbitration: International Commercial"},"content":{"rendered":"
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The importance and long-term consequences of the efficient resolution of commercial disputes is undoubted in the industrialized world. Until relatively recently, the principal burden has fallen on a limited number of national court systems that have traditionally captured the majority of such disputes. However, economic liberalization and technological change over the last two decades have profoundly altered the global economy. Business has responded through international expansion, cross-border partnerships and joint ventures of every description. This new "internationality" of business and trade patterns together with the uncertainties of unknown court systems and different procedures has jet-propelled the growth of international arbitration. Against this backdrop, Canadian businesses, legislators, courts and lawyers increasingly recognize, accommodate, respect and turn to arbitration as a preferred dispute resolution tool for international disputes.<\/font><\/span><\/p>

This has meant that the importance of domestic and international commercial arbitration in Canada<\/st1:place><\/st1:country-region> has grown markedly since the mid-1980s. The adoption of both the UNCITRAL Model Law on International Commercial Arbitration<\/i> (the "Model Law") and the New York Convention in 1986 together with dramatic increase in judicial deference toward arbitral tribunals has made arbitration in Canada<\/st1:place><\/st1:country-region>, or involving Canadian assets, far more attractive. At the same time, the increased participation by Canadian businesses in cross-border activity and the implementation of the North American Free Trade Agreement<\/i>, with its Chapter 11 investor\/state dispute resolution requirements, have also catalyzed growth.<\/font><\/span><\/p>

Canadians' Roles as International Arbitrators<\/font><\/span><\/b><\/p>

For those doing business and settling disputes in the international arena, national identities count, and Canadian arbitrators have a compelling advantage in this field. They are widely regarded to be knowledgeable, fair and non-partisan. The roots of this reputation reach back almost 50 years to when former Prime Minister Lester B Pearson won the Nobel Peace Prize in 1957. It is Pearson, and the many Canadian soldiers who have worn the UN's blue beret over the years, who seeded the now-institutionalized icon of Canadians as responsible, reliable neutrals on the world stage. (See "The New Peace Keepers," by Julius Melnitzer, The Canadian Lawyer, August 2004, http:\/\/www.mcmillanbinch.com\/Upload\/News\/JWRowley_TheNewPeacekeepers_0804.pdf.<\/i>)<\/font><\/span><\/p>

This has permitted an elite group of Canadian lawyers to take advantage of Canada<\/st1:place><\/st1:country-region> 's reputation for fairness and to punch way above the country's weight—economic or otherwise—as international arbitrators. Indeed, six Canadians have acted as "neutrals" in 11 of the 48 largest arbitrations with a European connection since 2001. More impressively, these same six have sat or are sitting on 11 of the world's largest cases, with just under $55 billion at stake.<\/font><\/span><\/p>

Law on Arbitration<\/font><\/span><\/b><\/p>

Canada<\/span><\/st1:country-region><\/st1:place> is a federal state whose constitutional peculiarities give the appearance<\/i> of complexity to the legislation governing commercial arbitration. Although legislation has been enacted federally, and by each of Canada<\/st1:country-region><\/st1:place> 's ten provinces and three territories, the complexity is more apparent than real. As a matter of practice, the laws of the various jurisdictions are remarkably similar. Differences that do exist are not sufficiently material to encourage forum shopping.<\/span><\/font><\/p>

With the exception of Quebec<\/st1:state>, each of Canada<\/st1:place><\/st1:country-region> 's provinces and territories has two arbitration statutes: one for domestic arbitrations and another for international arbitrations. Although Quebec<\/st1:state> is governed by civil law and the rest of Canada<\/st1:country-region><\/st1:place> by common law, any differences between the two with respect to arbitration are differences of form, not substance.<\/font><\/span><\/p>

The applicable federal statute, the Commercial Arbitration Act<\/i> (R.S.C. 1985, c.C-34.6), governs both domestic and international commercial arbitrations but is limited to disputes involving the federal government, federal Crown corporations and certain enumerated federal agencies. All other arbitrations are governed by provincial or territorial law.<\/font><\/span><\/p>

Court decisions are important sources of law governing arbitrations, especially insofar as the decisions interpret the legislation. And, although Quebec<\/st1:state> is a civil law jurisdiction, court decisions tend to play a larger role in Quebec<\/st1:place><\/st1:state> than they do in other civil law jurisdictions. At the same time, the civil law notion of doctrine plays a more important role in Quebec<\/st1:state> than in the remainder of Canada<\/st1:place><\/st1:country-region>.<\/font><\/span><\/p>

Principal Institutions<\/font><\/span><\/b><\/p>

The AAA, the ICC and the LCIA all maintain a direct or indirect presence in Canada<\/st1:country-region><\/st1:place> : the LCIA through Canadian representation on its North American Users' Council, the ICC through its Canadian National Committee and the AAA through the inclusion of Canadian members on its panel of distinguished neutrals.<\/font><\/span><\/p>

Three provinces host active arbitration institutions with the experience, staff and facilities to administer either domestic or international arbitrations. In Ontario<\/st1:state>, see the ADR Institute of Canada<\/st1:country-region>, Ottawa<\/st1:city>, www.adrcanada.ca<\/i>; and ADR Chambers, Toronto<\/st1:city><\/st1:place>, www.adrchambers.com<\/i>. In Quebec<\/st1:state>, see the Quebec National and International Arbitration Centre, Montreal<\/st1:place><\/st1:city>, www.cacniq.org. In British Columbia<\/st1:state>, see the British Columbia International Commercial Arbitration Centre, Vancouver<\/st1:city><\/st1:place>, www.bcicac.com<\/i>.<\/font><\/span><\/p>

Role of the Courts<\/font><\/span><\/b><\/p>

Since implementation of the Model Law, Canadian courts have demonstrated a clear shift in policy in favour of arbitrations over court proceedings. On at least two occasions—in Automatic Systems Inc. v. Bracknell Corp<\/i>. (1994) 18 O.R. (3d) 257, and in Canadian National Railway Co v. Lovat Tunnel Equipment Inc<\/i>. (1999) 174 D.L.R. (4th) 385—the Ontario Court of Appeal has stated that any ambiguities in the interpretation of arbitral legislation or agreements should be resolved in favour of arbitration.<\/font><\/span><\/p>

Canadian courts regularly implement Article 8(1) of the Model Law, which requires the stay of a judicial proceeding in favour of an arbitration where one party wishes to enforce the arbitration agreement (see Automatic Systems Inc v. Bracknell Corp<\/i>. [1994] 18 O.R. [3d] 257). Moreover, if a party to a foreign arbitration agreement commences Canadian judicial proceedings, the arbitration agreement notwithstanding, the opposing party may still apply to the Canadian court for a stay of the Canadian judicial proceedings on the basis of the arbitration agreement. The Canadian court would then have to determine and apply the law governing the arbitration agreement itself. If that law, like Canadian law, gives primacy to arbitrations and provides for stays of conflicting judicial proceedings, a Canadian court would be likely to exercise its discretion to stay the conflicting Canadian proceeding.<\/font><\/span><\/p>

Competence<\/font><\/span><\/b><\/p>

All Canadian jurisdictions have adopted Article 16 of the Model Law, thereby permitting the arbitral tribunal to determine its own jurisdiction, including objections with respect to the existence of an arbitration agreement. Domestic arbitrations are governed by similar principles. For example, section 17(1) of the Ontario Arbitration Act<\/i> provides that "an arbitral tribunal may rule on its own jurisdiction to conduct the arbitration and may in that connection rule on objections with respect to the existence or validity of the arbitration agreement."<\/font><\/span><\/p>

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Useful References<\/font><\/span><\/b><\/p>

H. Alvarez, "Recent Trends in International Commercial Dispute Resolution," (1999) 57 Advocate<\/i> 691.<\/font>B. Barin, Carswell's Handbook of International Dispute Resolutions Rules<\/i>, (Scarborough, Ont.: Carswell, 1999).<\/font><\/span>Canadian Encyclopaedic Digest<\/span><\/i><\/font> (Ontario<\/st1:state> ), vol. 1A, 3rd ed. (Scarborough<\/st1:place>, Ont.: Carswell, 2001) 'Arbitration.'<\/font><\/span><\/font>J.B. Casey and J. Mills, Arbitration Law of Canada: Practice and Procedure<\/i> (New York<\/st1:state><\/st1:place> : Juris, forthcoming 2004).<\/font><\/span>E.C. Chiasson, "A Precipice Avoided: Judicial Stays and Party Autonomy in International Arbitration" (1996) 54 Advocate (Van.) 63.<\/font>L.Y. Fortier, "Delimiting the Spheres of Judicial and Arbitral Power: 'Beware, My Lord of Jealousy'" (2001) 80 Can.<\/st1:place><\/st1:country-region> Bar. Rev. 143.<\/font><\/span>G.W. Ghikas, "The Independence<\/st1:city> and Impartiality of Arbitrators: A Perspective from British Columbia<\/st1:place><\/st1:state>," (1999) 57 Advocate 9 (Van.) 677.<\/font><\/span>D.R. Haigh, A.K. Kunetzki & C.M. Antony<\/st1:place><\/st1:city>, "International Commercial Arbitration and the Canadian Experience," (1995) 34 Alta. L.Rev.137.<\/font><\/span>International Commercial Arbitration in the New Millennium\/Continuing Education Program<\/span><\/i><\/font> (Toronto<\/st1:city><\/st1:place>, Ont.: Canadian Bar Association, 2001).<\/font><\/span><\/font>P.D. McCutcheon & C.B. Todgham, The Canadian Experience: Second Generation Legislative Improvements<\/i> (Toronto, Ont.: Unknown, 1990).<\/font>J. William Rowley, Q.C., Arbitration World: Jurisdictional Comparisons<\/i> (London<\/st1:city><\/st1:place>, Eng: European Lawyer, 2004).<\/font><\/span>J.C. Thomas, "Investor-State Arbitration under NAFTA," (1999)<\/font> 37 Can.Y.B. Int'l L.99.<\/font><\/i><\/font>T. Weiler, NAFTA Investment Arbitration and Growth of International Economic Law<\/i> [2002] B.K.I. 158.<\/font><\/span><\/p><\/blockquote>

Agreement to Arbitrate<\/font><\/span><\/b><\/p>

Article 7 of the Model Law applies to the formal requirements of arbitration agreements throughout Canada<\/st1:country-region><\/st1:place> in respect of international arbitrations.<\/font><\/span><\/p>

Arbitrability<\/font><\/span><\/b><\/p>

As a general rule, there are no restrictions on the types of normal commercial matters that may be referred to arbitration. All Canadian jurisdictions have adopted Article 16 of the Model Law, which provides that the arbitration agreement is independent of the contract in which it is found. Canadian courts have also long held that, for domestic purposes, arbitration clauses are severable from the contract in which they are found (see Heyman v. Darwings Ltd<\/i> [1942] A.C. 356 [H.L.]).<\/font><\/span><\/p>

Qualification\/Appointment\/Liability of Arbitrators<\/font><\/span><\/b><\/p>

As a general rule, there are no formal citizenship, residency or professional requirements for arbitrators. All arbitrators must, however, be independent and impartial. Although the Model Law and various Canadian statutes are worded slightly differently in this regard, it is unlikely that a court would ascribe any difference in meaning to the difference in wording. The Model Law imposes a continuing obligation on an arbitrator to disclose any circumstances likely to give rise to justifiable doubts as to his or her "impartiality or independence." Domestic legislation also imposes a continuing obligation to disclose any circumstances giving rise to a "reasonable apprehension of bias." It is most likely that reasonable apprehension of bias is simply the Canadian common law articulation of impartiality and independence. The test under this rubric is not whether the arbitrator is biased but whether an objective observer could reasonably apprehend that the arbitrator is biased.<\/font><\/span><\/p>

Canadian legislation is silent on the civil liability of arbitrators both in the international and domestic context. However, the legislation of certain provinces (for example Alberta, British Columbia and Ontario) provides that an arbitrator who is removed for a fraudulent or corrupt act or for undue delay may be denied payment for services and may be required to compensate the parties for all or part of the costs incurred in connection with the arbitration before the arbitrator's removal. As a general rule, Canadian civil and common law jurisdictions hold that arbitrators are immune from claims of negligence or breach of contract (Zittrer v. Sport Mask Inc.<\/i> [1988] 1 SCR 564 [S.C.C.]). In recent years the law has evolved to limit immunity only to arbitrators who exercise "judicial" functions such as hearing evidence and making determinations of fact and law. Those who act in a capacity more like a valuator or an expert may not enjoy immunity (see Zittrer<\/i>, supra).<\/font><\/span><\/p>

Party Representation<\/font><\/span><\/b><\/p>

Arbitration legislation does not impose any formal requirements for party representatives who act as "counsel" on an arbitration. However, most provinces have rules that restrict the ability to practiSe law in the province to lawyers who are licensed to practiSe law in Canada<\/st1:place><\/st1:country-region>. In domestic arbitrations applying Canadian law, "counsel" who are not licensed to practise law in Canada<\/st1:country-region><\/st1:place> may run into difficulty with these rules. However, in international arbitrations, particularly those applying the law of another state, this is not likely to be the case.<\/font><\/span><\/p>

Place of Arbitration\/Proceedings<\/font><\/span><\/b><\/p>

Canadian law leaves the location of the arbitral proceedings to a combination of the parties and the arbitral tribunal. For international arbitrations, Canadian laws generally provide expressly that the parties may agree on the place of arbitration and that, failing such agreement, the tribunal determines the location (Model Law Article 20). As well, all the provincial\/territorial laws regarding international arbitrations provide that an award shall be deemed to have been made at the place of arbitration selected.<\/font><\/span><\/p>

There are relatively few procedures specified for international arbitrations. These are also generally subject to any agreement by the parties to the contrary. However, parties must submit statements outlining the relevant facts, points at issue and relief sought, together with relevant documents (Model Law Article 23[1]), and the arbitrator must provide the parties with sufficient advance notice of any hearing or meeting (Model Law Article 24[2]).<\/font><\/span><\/p>

Evidence Gathering<\/font><\/span><\/b><\/p>

Procedures in Canadian seated international arbitrations tend to follow international norms. Oral examinations for discovery tend to be discouraged, and documentary production may be circumscribed. The production requirements of the IBA Rules of Evidence<\/i> are increasingly relied upon. Hearings also tend to be more streamlined in international arbitrations, for example, with evidence introduced by way of pre-filed witness statements, agreed time limits and the exchange of written submissions.<\/font><\/span><\/p>

Arbitrators in international arbitrations have fewer express powers (compared with domestic arbitrators) regarding witnesses and production. Articles 23, 24, 25 and 27 of the Model Law apply to evidence in international commercial arbitrations. Thus an arbitrator or a party (with the approval of the arbitrator) may request the assistance of a domestic court in taking evidence, and the court may act on that request according to its own rules on taking evidence.<\/font><\/span><\/p>

Interim Measures\/Role of the Tribunal<\/font><\/span><\/b><\/p>

In international arbitrations, Article 17 of the Model Law permits an arbitrator to order a party to take whatever interim measures of protection are considered to be necessary in respect of the subject matter of the dispute.<\/font><\/span><\/p>

Taxation of Arbitrators' Fees<\/font><\/span><\/b><\/p>

Canada<\/span><\/st1:country-region> does not treat foreign arbitrators differently from any other foreign persons earning income from activities in Canada<\/st1:country-region><\/st1:place>. The extent of any arbitrator's liability for Canadian taxes on his or her arbitration fees will turn on the extent of arbitration activity in Canada, the degree to which the arbitrator is resident in Canada and the existence and provisions of any tax treaties between Canada and the arbitrator's country of residence. Theoretically, Canadian tax laws may require a portion of any arbitration fees paid to a non-resident arbitrator for work carried out in Canada to be withheld and remitted to the Canadian tax authority on account of the arbitrator's potential income tax liability, subject to the arbitrator's right to claim a refund of the amount withheld in appropriate circumstances. However, as a practical matter, most foreign arbitrators will not pay—and Canada<\/st1:country-region> and the provinces will not seek—Canadian taxes on fees from occasional arbitrations in Canada<\/st1:place><\/st1:country-region>.<\/span><\/font><\/p>

Default Proceedings<\/font><\/span><\/b><\/p>

In both domestic and international arbitrations, the tribunal may continue the proceedings and make an award on the evidence before it if a party fails to appear at a hearing or to produce documentary evidence without providing a satisfactory explanation (see, for example, Ontario Arbitration Act<\/i> section 27[3] and Model Law Article 25[c]).<\/font><\/span><\/p>

The Arbitral Award<\/font><\/span><\/b><\/p>

Awards in both domestic and international arbitrations must be made in writing. Awards must also be signed, dated and indicate the place where they were made. Unless the parties agree otherwise, awards must state the reasons upon which they are based. A copy of the award must be delivered to each party. See, for example, Ontario Arbitration Act<\/i> section 38 and Model Law Article 31.<\/font><\/span><\/p>

In international arbitrations, the tribunal may impose such remedies as are permitted by the rules of law determined to apply to the substance of the dispute (Model Law Article 28). These remedies must be in accordance with the terms of the underlying contract and must take into account any usages of the trade applicable to the transaction. International tribunals may impose remedies on the basis of decisions made ex aequo et bono<\/i> or as amiable compositeur<\/i>, but only if expressly authorized to do so by the parties. Canadian legislation governing international arbitrations contains no specific provisions with respect to interest or costs, and the tribunal's power to award interest or costs will turn on the arbitration agreement between the parties.<\/font><\/span><\/p>

Recourse from an Award<\/font><\/span><\/b><\/p>

In both domestic and international arbitrations a party may request the tribunal to explain or interpret any aspect of the award. Tribunals in both domestic and international arbitrations may also, either on their own initiative or at the request of any party, correct errors in the nature of typographical, computation or similar errors (see, for example, Ontario Arbitration Act<\/i> section 44[1][a] and Model Law Article 33[1]). Finally, tribunals in both domestic and international arbitrations may make an additional award to deal with claims presented in the arbitration but omitted from the earlier award (see, for example, Ontario Arbitration Act<\/i> section 44[2] and Model Law Article 33[3]).<\/font><\/span><\/p>

Awards arising from international arbitrations may not be appealed but may be set aside by the courts on certain enumerated grounds (Model Law Article 34). Again, these grounds relate principally to issues of jurisdiction and due process. They include, for example, the invalidity of the arbitration agreement, the arbitration of a dispute that was beyond the scope of the arbitration clause or if the arbitral procedure was not in accordance with the parties' agreement.<\/font><\/span><\/p>

Reviews have generally been seen to be much more limited than appeals, with considerable respect being shown to the concept of finality of an international tribunal's award. However, one Canadian superior court judge recently interpreted his jurisdiction to review a NAFTA panel's decision to include an ability to review and criticize the panel's interpretation of NAFTA itself on the theory that, in effect, the panel's "error" took the dispute beyond the scope of the arbitration clause. In the result, the judge set aside most of the panel's decision. Although the case has attracted considerable criticism, it raises questions about whether international arbitration decisions will now be subject to appeals disguised as reviews. See Mexico<\/i><\/st1:place><\/st1:country-region> v Metalclad Corp.<\/i> [2001] BCSC 664.<\/font><\/span><\/p>

Enforcement of Award<\/font><\/span><\/b><\/p>

The enforcement of foreign arbitral awards in Canada<\/st1:country-region><\/st1:place> is governed by the New York Convention. Awards rendered in international arbitrations, whether rendered in Canada<\/st1:place><\/st1:country-region> or elsewhere, may also be enforced in Canadian jurisdictions by application to the domestic courts (Model Law Articles 35 and 36). The applying party must supply the award and the original arbitration agreement, translated into French or English if necessary. The domestic court must then render an enforcement judgment, unless any of the grounds for setting aside an international arbitral award exist.<\/font><\/span><\/p>

Confidentiality of Proceedings<\/font><\/span><\/b><\/p>

Historically, arbitrations have been regarded as confidential to the parties. However, there are no specific legislative provisions requiring that any particular part of the arbitration be conducted confidentially, nor have Canadian courts dealt definitively with the differences that have arisen on this subject in the U.K. on the one hand (inherent confidentiality) and in the U.S., Australia and Sweden on the other (no inherent confidentiality). Nevertheless, the decision in 887574 Ontario Inc v. Pizza Pizza<\/i> [1994] O.J. No. 3112 lends support for confidentiality by holding that arbitral proceedings are in the "private confidential sectors."<\/font><\/span><\/p>

In any event, it is common for the parties to agree that some or all aspects of the arbitration are to be confidential, and such an agreement is enforceable. Moreover, even without such arrangements, an arbitration is private in the sense that members of the public may not insist on attending hearings. If any matter is referred to a court, however, any confidentiality arrangement must give way to the court's rules with respect to public access to judicial proceedings. Generally speaking, court records and proceedings are open to the public unless sealed, and sealing orders are granted only in exceptional cases. See, for example, Ontario's Courts of Justice Act<\/i>, R.S.O. [1990], C.C43. sections 135 and 137, and CTV Television Inc. v. Ontario Superior Court of Justice<\/i> [April 2, 2002] Docket CA C35819 (Ont. C.A.<\/st1:country-region><\/st1:place> ).<\/font><\/span><\/p>

Unique Jurisdictional Attributes<\/font><\/span><\/b><\/p>

Canadian law and practice have evolved to the point where arbitration agreements and arbitral awards are accorded a high degree of respect, protection and enforcement. Canadian courts have become increasingly vigilant in preventing parties from escaping their agreements to arbitrate and also increasingly deferential to arbitral awards on appeal and on applications to review. Commercial arbitrations are becoming more and more common, and there are a growing number of arbitral institutions and affiliated and unaffiliated arbitrators of considerable expertise. Arbitrations appear likely to continue to grow in importance as a preferred method for resolving business disputes.<\/font><\/span><\/p>

J. William Rowley, Q.C.<\/strong> •<\/font> Tel: (416) 865-7008 • Fax: (416) 865-5519 •<\/font> Email: wrowley@mcmillanbinch.com<\/a>David W. Kent<\/strong> •<\/font> Tel: (416) 865-7143 • Fax: (416) 865-7048 •<\/font> Email: david.kent@mcmillanbinch.com<\/a><\/font><\/span>&Markus Koehnen<\/strong> •<\/font> Tel: (416) 865-7218 • Fax: (416) 865-7048 •<\/font> Email: markus.koehnen@mcmillanbinch.com<\/a><\/font><\/span>McMillan Binch Mendelsohn LLP<\/font><\/span><\/i>4400 BCE Pl, 181 Bay St, Bay Wellington<\/st1:city><\/st1:place> Twr,<\/font><\/span> Toronto<\/span><\/st1:city> ON<\/st1:state>   M5J 2T3<\/st1:postalcode><\/span><\/font><\/st1:place>www.mbmlex.com<\/font><\/a><\/span><\/p><\/div>","protected":false},"excerpt":{"rendered":"

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