closely connected with. Whether or not
such connection exists is always a matter
of the specific circumstances which would
be taken into consideration by the courts
or arbitral tribunals when deciding a
dispute. However, there are a couple of
concept. For instance, in a real estate
sales contract, the latter is presumed to be
most closely connected with the country
where the real estate is.
The predominantly dispositional
character of the "conflict of law" rules,
as well as the wide scope of assessment
relation, make this type of approach
in determining the applicable law
unattractive to the merchants. In order
to avoid these inconveniences, it is in
the parties' best interest to choose the
governing law expressly.