Abstract

To the exclusion of cases when the Convention is applied to a purely domestic contract, CISG is applied only to contracts for the international sale of goods, that is in a situation whereby both contracting parties have their places of business in two diff erent states. If both states are parties to the Convention, it will be applied directly. If even one party to a contract for the international sale of goods operates in a non-Convention state, CISG may be applied indirectly if under the International Private LAw forum the law of a Convention state is indicated as lex contractus for a given contract. Regardless of whether CISG would be directly or indirectly applicable, it is necessary to check each time whether the states where places of business of the contracting parties are located or the Convention state whose law has been indicated as lex contractus have made a reservation under Art. 92-96 of the Convention. Such reservations may signifi cantly aff ect the extent of application of CISG. Not without meaning are also intertemporal provisions of the Convention, which make it possible to answer the question since when CISG will be applied in each case of its ratifi cation by a new state, like e.g. recently Brazil, in relation to which the Convention became eff ective as of 1 April 2014.