Geographical remoteness has not prevented Australia from pursuing a persistent ambition to become a major hub for international commercial arbitration (ICA). While regional competitors in the Asia-Pacific region such as Singapore and Hong Kong have already achieved great success in the arbitration world, Australia’s ‘Tyranny of Distance’1 requires that extra efforts be made to attract ICA cases. Recent marketing from Austrade within the Australian government2 emphasises the relative strengths of ICA in Australia: (1) a harmonised legal framework for ICA in line with international standards, (2) sophisticated arbitration institutions and (3) some of the world’s leading arbitration practitioners.

This chapter acts as a capstone to Part IV’s presentation of country reports. It presents the findings of a comparative analysis of arbitration laws in the different countries reported. This analysis focuses on the different issues presented in Parts I–III, including scope and interpretation of arbitration clauses, anti-arbitration laws and policies, arbitrator bias and misconduct, the public policy exception, and other limits on arbitrability. Thus, the country reports are reviewed here to determine areas of commonality and divergences across national laws relating to judicial intervention into the arbitration process. It will also assess possible trends in international commercial arbitration.