The principle of Closest Relationship in private international law and some recommendations to improve Vietnamese law

Abstract

As a specific phenomenon in the process of governing civil relationships with foreign elements, conflict between the International private Law requires the establishment of law selection principles to apply in specific situation. Provisions on the application of Closest Relationship to determine law when dealing with civil relationships with foreign elements  are newly built in the 2015 Civil Code which remains no specific guidelines. The article explores the principle of Closest Relationship under international treaties and national law around the world, thereby recommends some experience, contributing to the interpretation of this principle in Vietnam.