The circulation and legal transplant of the Spanish model of arbitration constituted by will in Latin America

between improvements and future prospects

Abstract

The article studies the evolution of the Spanish model of arbitration constituted by will, a model that has been used as inspiration in Latin America, in countries such as Bolivia, Peru and Honduras. Through a methodology in legal comparison, it will be observed how the initial Spanish model remains tendentially static, while Latin American legislators, adopting a more dynamic behavior, led to the creation of several models that improve the regulation from which inspiration has been taken.