admissible under the arbitration law of the seat of the Arbitral Tribunal. 2.9 UNCITRAL Model Law UNCITRAL (United Nations Commission on International Trade Law), is a United Nations agency specialising in international trade law, which has been created on the 17th December 1966 with the avowed aim of reducing disparities between the various commercial legal systems. These disparities have always been seen as obstacles to international trade and it was therefore important to minimise their impact. As we shall see, this problem greatly afects tourism, especially international tourism, which pits diferent states and diferent legal systems against each other. The Model Law on international arbitration, approved by UNCITRAL, was perhaps the most relevant legal instrument in the history of this agency, along with the arbitration rules known as the "UNCITRAL rules", which are expressly applied in multiple institutional arbitration tribunals around the world. This Model Law, as the name indicates, was intended to "inspire" the various countries when creating their own arbitration laws, which has been happening at an accelerated rate. The 2011 Portuguese Law is a clear example of this, having often translated the articles contained in the Model Law. Although the rules of international arbitration law are transnational in nature, the truth is that the rules that give them content usually come from national state sources. 2.10 Advantages and disadvantages of arbitration At this point, it is important to identify, albeit briefy, the main advantages and disadvantages of arbitration. While it is true that economic agents in countries like Portugal still look at arbitration with some mistrust, it is equally true that more and more people are resorting to these alternative forms of dispute resolution, which are showing signifcant growth. In the feld of the advantages of arbitration we highlight the speed of decisions, the possibility of the parties to choose the judges, the confdentiality of arbitration proceedings, the certainty that the arbitration agreement generates as to the way in which disputes will be resolved, the specialization of the arbitrators and the greater guarantees of neutrality that arbitration bodies ofer, compared to state jurisdictions, usually "home-made" when it comes to the confrontation of its law with the law of another state. This phenomenon is often caused by the normal unfamiliarity of the foreign legal order, which impels the judge to try to use the legal system that he knows and dominates best. One of the great advantages of resorting to international arbitration is the possibility of choosing the law applicable to the merits of the case. This enshrines the principle of autonomy of the will in Private International Law, which the Civil Code and the 1980 Rome Convention on the Law Applicable to Contractual Obligations (in force in Portugal since 1994) also embrace. Note that the law authorises the parties to choose a law, i.e. a legal system, and not simply to refer to general principles or to the principles common to the legal systems connected with the dispute. In the absence of a choice by the parties, the court will apply, according to Article 52(2), "the law of the State with which the subject-matter of the dispute has the closest connection". In order to determine this law, arbitrators must examine all the circumstances of the 7
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