近年来,国际仲裁可谓方兴未艾。随着中国市场的进一步开放和中国企业“走出去”步伐的加快,国际仲裁作为最主要的跨境争议解决机制,已经成为了中国企业的必修课。以国际货物买卖领域为例,今天几乎已经很难见到一个没有仲裁条款的买卖合同了。但是,国际仲裁非常复杂,实践中已经演变成为一个混合了大陆法系和英美法系诸多元素的综合体,值得中国的法律从业者们认真学习。笔者结合自己的工作经历,尝试总结国际仲裁与国内仲裁之间的几个重大 In recent years, international arbitration is booming. With the further opening up of the Chinese market and the acceleration of Chinese enterprises’ “going global”, international arbitration, as the most important cross-border dispute settlement mechanism, has become a compulsory course for Chinese enterprises. Take the international sale of goods as an example. It is almost impossible today to see a contract of sale without an arbitration clause. However, the complexity of international arbitration has in practice evolved into a complex in which many elements of the civil law system and Anglo-American law system are mixed, and it is worth studying conscientiously by Chinese law practitioners. Based on my own work experience, I try to summarize several important issues between international arbitration and domestic arbitration