The role of intellectual property in world trade and economic development is steadily growing. In the modern world, where the economy is increasingly dependent on the use of the results of intellectual activity, the results of the intellectual labor of citizens are the potential of the state, the key to international competitiveness and national prosperity. However, prosperity is impossible without the proper level of legal protection of intellectual rights. This thesis is devoted to a comparative study of the arbitrability of intellectual property disputes in different legal systems. The purpose of the study is to summarize the current trends in the legislation of different countries and international judicial and arbitration practice on the issue of arbitrability. Based on the results of the analysis and critical reflection of doctrinal sources and national laws, a gradual expansion of the range of arbitrable categories of disputes, and the liberalization of this area, are being made. However, existing restrictions are often not explicitly enshrined in legislation. In addition, significant differences remain between the legislation of different countries on certain issues, in particular regarding the validity of intellectual property rights. It seems logical that in order to harmonize international legislation, it is necessary over time to single out uniform criteria for arbitrability and consolidate them at the level of international acts. After examining an international trend of arbitrability of intellectual property, this paper analyses the challenges of intellectual property protection in Kyrgyzstan and the place of arbitration.