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.