Act Governing the Choice of Law in Civil Matters Involving Foreign Elements Article 20

(1) The applicable law regarding the formation and effect of a juridical act which results in a relationship of obligation is determined by the intention of the parties.(2) Where there is no express intention of the parties or their express intention is void under the applicable law determined by them, the formation and effect of the juridical act are governed by the law which is most closely connected with the juridical act.(3) Where among the obligations resulting from a juridical act there is a characteristic one, the law of the domicile of the party obligated under the characteristic obligation at the time he /she undertook the juridical act is presumed to be the most closely connected law. However, where a juridical act concerns immovable property, the law of the place where the immovable property is located is presumed to be the most closely connected law.