Subparagraph (a) of Article 10 is a CISG innovation. Subparagraph (b) is comparable to ULIS Article 1(2) and ULF Article 1(2).
CISG Article 10 ULIS Article 1(2) and ULF Article 1(2) For purpose of this Where a party to the contract Convention: does not have a place of business, reference shall be (a) if a party has more than made to his habitual residence. one place of business, is [ULF Article 1(2) is identical] that which has the closest relationship to the contract and its performance, having regard to the circumstance known to or contemplated by the parties at any time before or at the conclusion of the contract; (b) if a party does not have a place of business, reference is to be made to his habitual residence.
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