Lex loci contractus

Lex loci contractus is the law of the place where a contract is made. Historically it helped courts choose the governing law for cross-border contracts. Today it has limited independent force in many systems, including Swiss practice, because party autonomy and more specific connecting factors usually prevail, such as the characteristic performance or the closest connection. The concept still appears in comparative discussions and may matter where formation, formal validity or older conflict rules are in issue.