12.1 Which law(s) apply to arbitration in Singapore?

Singapore currently has two arbitration regimes and two different sets of arbitration laws, i.e the International Arbitration Act (“IAA”) and the Arbitration Act (“AA”). As the name suggests, the International Arbitration Act is geared towards international arbitrations, whereas the Arbitration Act is regulating domestic arbitration matters. The International Arbitration Act applies, provided there is a “foreign” element in it, which is for instance present, if at least one of the parties to an arbitration agreement, at the time of the conclusion of the agreement, has its place of business in any State other than Singapore; or one of the following places is situated outside the State in which the parties have their places of business: (i) the place of arbitration if determined in, or pursuant to, the arbitration agreement; or (ii) any place where a substantial part of the obligations of the commercial relationship is to be performed or the place with which the subject-matter of the dispute is most closely connected or the parties have expressly agreed that the subject-matter of the arbitration agreement relates to more than one country