Turnkey Construction Projects in Private International Law

The paper presents a research of the different approaches to the legal regulation of international "turnkey" construction projects. The first part of the paper is devoted to the general theoretical aspects regarding such projects elaborated by the international nongovernmental and expert bodies forming lex constructionis as a subdivision of lex mercatoria. In the second part of the paper author performs a comparative research of approaches to international "turnkey" projects' regulation including the practical aspects of the industry (based on the various construction contract proformas) developed in the United Kingdom and Russia. In the final part of the paper author analyses disputes and litigation cases specific for the "turnkey" projects and studies new collaborative contractual models currently developing in the industry and directed to the minimization of disputes. After that author points out some problematic matters of international traditional and collaborative contracting models' implementation in Russia. Finalizing the paper there are conclusions about the overall efficiency of the collaborative contractual models comparing to the traditional ones with respect to "turnkey" construction projects and recommendations regarding further reception of international regulative approaches for construction industry into Russian legal system.