GOVERNING LAW IN TRANSNATIONAL CORPORATE CONTRACTS: A COMPARATIVE STUDY (UZBEKISTAN & GERMANY)

This article examines the role, selection, and implications of governing law in transnational corporate contracts, focusing on the comparative legal frameworks of Uzbekistan and Germany. The study explores how contractual parties determine applicable law, the interaction between domestic legislation and international instruments, and the practical considerations influencing parties’ choices in international commerce. Special emphasis is placed on predictability, party autonomy, enforceability, and the impact of public policy constraints. The research also analyzes how globalization has transformed private international law and the governance of cross border business relationships. The paper concludes that while both Uzbekistan and Germany emphasize party autonomy, they differ in legal traditions, interpretive methods, and regulatory constraints, which shape the practical outcomes of governing-law clauses in corporate practice. The study contributes to understanding how multinational firms can optimize contract drafting, dispute resolution, and commercial strategy through informed choices of applicable law.^[1]