This work analyzes the reimbursement for attorney's fees with regard to the applicable national laws of Switzerland, Germany, France, England, and the US, and with regard to the international arbitration rules and the Contracts for the International Sale of Goods. The book focuses on the allocation of attorney's fees in contract and tort cases and business law. Divided into three parts, it deals with civil procedure rules, international arbitration, and national substantive laws. It detects contradictions in the rules and principles, and it argues persuasively for the creation of a general fee-shifting rule.