ABSTRACT
The Rome Convention on the Law Applicable to Contractual Obligations was eventually opened for signature on 19 June 1980. The legal basis of the Rome Convention, in contradistinction to the Brussels Convention, is not specifically derived from the provisions of article 220 of the Treaty of Rome. Considerable controversy arose during negotiations over the question of conferring jurisdiction on the European Court of Justice to interpret the provisions of the Rome Convention, stemming from the fact that the Convention lacked rigid legal basis under the Treaty of Rome. Article 18, which has no equivalent in the Brussels Convention 1968, is an important element in the Convention interpretation system. The Rome Convention applies to contractual obligations in any situation involving a choice between the laws of different countries, provided that such obligations are within its scope. The Convention is not intended to apply to purely domestic disputes, but only to those involving ‘a choice between the laws of different countries’.
