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Hochtief v. Argentina

Type of decisionDecision on Jurisdiction
Date of decision24 October 2011
Tribunal
Vaughan Lowe (President)
Charles N. Brower
Christopher Thomas (dissenting)
Legal instrumentBIT between Argentina and Germany (1991)
Further information

Statements from this decision

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While different tribunals should seek to act consistently with one another, there is no doctrine of precedent
IITs must be interpreted using the rules of interpretation laid down in the VCLT
Minority shareholdings can constitute investments
The invocation of a waiting clause constitutes a treatment within the territory of the host state
An MFN clause does not purport to give investors further rights in addition to those given under the IIT
An MFN clause does not permit an investor to selectively pick provisions from several IITs; the investor has to rely on the whole scheme of one IIT, e.g. a dispute settlement clause
In case investors of a different nationality are granted a choice between litigation and arbitration, a foreign investor without that choice is treated less favourable
Not every activity falls within the scope of an MFN clause
The opportunity to commence an arbitration without observing a waiting clause is not a distinct right; it concerns the exercise of an existing right to arbitrate and thus is within the scope of an MFN clause
If an IIT provides that "the management [...] of an investment" falls within the scope of an MFN clause, the clause applies to dispute settlement provisions
The opportunity to commence an arbitration without observing a waiting clause is not a distinct right; it concerns the exercise of an existing right to arbitrate and thus is within the scope of an MFN clause
The observance of a waiting clause is a requirement of a claim's admissibility, not a tribunal's jurisdiction
If a dispute settlement clause requires a claim's submission to national courts on a party's request only, the submission is not mandatory without such a request
A party may take the position that the parties are still "in dispute" despite a domestic court's decision
A duty to attempt settlement before domestic courts and an obligation to exhaust local remedies may have different effects
If a dispute settlement clause requires a claim's submission to national courts only on a party's request, it may be argued that such a submission is nevertheless mandatory before commencing the arbitration
A duty to attempt settlement before domestic courts and an obligation to exhaust local remedies may have different effects
Jurisdictional clauses in contracts providing for domestic court proceedings between the host state and a domestic company are of no relevance for the jurisdiction of a treaty-based tribunal in an arbitration commenced by the foreign shareholder of the domestic company
A tribunal has to differentiate between questions of jurisdiction and admissibility
The parties to a dispute cannot alter the jurisdiction of an IIT tribunal; the tribunal may still have competence to hear and decide the case, but it would act as an ad hoc tribunal
A state's consent to arbitration is expressed in the IIT
A tribunal has a duty to determine its jurisdiction sua sponte
The risk of double recovery is not relevant when determining a tribunal's jurisdiction
The observance of a waiting clause is a requirement of a claim's admissibility, not a tribunal's jurisdiction
IITs must be interpreted using the rules of interpretation laid down in the VCLT
A duty to attempt settlement before domestic courts and an obligation to exhaust local remedies may have different effects

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