Both the November 2015 EU Commission proposal for Investment Protection and Resolution of Investment Disputes in the EU-US TTIP as well as the revised February 2016 version of the Canada-EU CETA contain an investment court system (ICS) which is a two-tier mechanism for investor-State dispute settlement (ISDS), combining elements of traditional investor-State arbitration (ISA) with judicial features. The resulting hybrid form of dispute settlement should be regarded as a permissible inter se modification of the ICSID Convention.
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