Arbitration in Hong Kong. The Sliding Scale Between Two Systems

This essay, after a reconstruction of the fundamental elements of the legal formula behind the "one country, two systems" priciple in the field of arbitration, analyses the evolution of the legal regime of arbitration in Hong Kong and China. The research focuses on the issue of cross border arbitration relationship between the two systems, dealing in particular with those related to public policy as a legal ground to refuse enforcement requests. In the last part of this work an analysis of an important case, the so called Keeneye case, will be made. This case is seen as the expression of a new approach to the principle of "one country, two systems" in arbitration.