Abstract
The thrust of this article is to examine a contemporary international arbitration process in
commercial and investment cases, specifically the interplay of common law and civil law elements
in the taking of evidence. It begins with a survey of the provisions of the most popular
international arbitration instruments, including international arbitration rules and IBA
Rules on the Taking of Evidence in International Arbitration. Following the discussion of
some relevant examples of international arbitration instruments, the author tries to answer
the question whether these instruments, in their current form, support the popular thesis
that the international arbitration process has become largely harmonized. In trying to verify
this thesis, the article also goes beyond the text of international arbitration instruments and
considers the influence of the cultural biases of international arbitration actors.
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