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Investor Presentaiton

21 investors direct access to international arbitration against host States. This is, however, a key initial decision to make, and contracting parties to a particular IIA should consider it carefully, weighing the pros and cons. Should they decide to include an ISDS mechanism in the treaty, this sequel can help to shape and tailor it in ways that would meet their requirements and policy objectives. The sequel aims to systematically analyse the components of ISDS and to take stock of developments in the relevant IIA provisions. Most IIAs have a similar structure, yet provisions in different treaties often vary significantly. Those variations often have a significant effect on issues such as the breadth of the host State's consent to arbitration, venues where arbitration can be held, remedies available to claimants and many others. This paper seeks to explain the rationale for, and implications of, particular treaty approaches to relevant ISDS issues. Many of these issues are legal and technical in character; however, they may make a significant difference in specific disputes. The sequel's analytical approach is meant to inform future policy decisions so that the paper may serve as a toolkit for IIA negotiators. In its closing section, the paper puts this technical discussion into the broader context and outlines five paths for the reform of the ISDS system." This paper is structured as follows. Section I briefly sets out the historical background of ISDS, and then identifies the salient features of the system and the main criticisms of it. Section II undertakes a review of treaty practice with respect to individual ISDS issues, such as consent to arbitration, the scope of ISDS, available dispute settlement forums, frivolous claims, applicable substantive law, the role of States in the interpretative process, remedies, and many others. It seeks to identify the rationales for, 8 Another useful tool is International Investment Agreements Negotiators Handbook: APEC/UNCTAD Modules (APEC, 2013). 9 See also UNCTAD, 2013b, pp. 112-117. UNCTAD Series on International Investment Agreements II
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