The re-characterisation of limitation provisions as substantive (from Pfeiffer and Zhang) applies to contractual claims, not only tort claims. A plaintiff cannot rely on an alternative 'knowledge-based' limitation period in foreign limitation legislation by arguing that the relevant 'knowledge' includes awareness of changes in the forum's choice of law rules. Where the lex fori and lex causae share the same choice of law rule and apply it the same way, renvoi does not arise.
The full text is available to signed-in members.