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Investor Presentaiton

85 relevant administrative remedies in Colombia and not in Canada, pointing to the possibility of asymmetrical solutions in this sphere. The Trilateral Investment Agreement between China, Japan and the Republic of Korea (2012) contains a four-month administrative- review requirement: "7. When the disputing investor submits a written request for consultation to the disputing Contracting Party under paragraph 2 [a pre-requisite for filing an ISDS claim], the disputing Contracting Party may require, without delay, the investor concerned to go through the domestic administrative review procedure specified by the laws and regulations of that Contracting Party before the submission to the arbitration set out in paragraph 3. The domestic administrative review procedure shall not exceed four months from the date on which an application for review is filed. If the procedure is not completed by the end of the four months, it shall be deemed to be completed and the disputing investor may submit the investment dispute to the arbitration set out in paragraph 3." (Article 15). This approach does not make recourse to administrative procedure mandatory; rather, it leaves it to the respondent State to decide in each case whether it wishes the particular investor to go through domestic administrative review before the ISDS proceedings are commenced. A limited number of agreements require that an investor must first exhaust the host State's administrative remedies. The BIT between China and Côte d'Ivoire (2002) is a case in point: "Article 9. Settlement of disputes between investors and One Contracting Party [...] UNCTAD Series on International Investment Agreements II
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