国际商事仲裁与国际民事诉讼相比内容更为复杂,在法律选择上当事人也有更为广阔的空间。然而这也产生了当事人意思自由与强制法规定相冲突的矛盾,并集中体现在我国《合同法》第126条第2款的规定中。本文在分析了国际商事仲裁复杂性的基础上,探讨有关国内法律在仲裁中的适用问题,意在使得国际商事仲裁实现其真正价值。 International commercial arbitration is more complicated than international civil lawsuit, and there is more room for the parties in the choice of law. However, this also resulted in the contradiction between the freedom of intention of the parties and the provisions of the compulsive law, and was embodied in the stipulation of Article 126, paragraph 2, of the Contract Law of our country. Based on an analysis of the complexity of international commercial arbitration, this article explores the application of domestic law in arbitration with the aim of making it possible for international commercial arbitration to realize its true value.