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Alps Finance v. Slovakia

Type of decisionAward
Date of decision5 March 2011
Tribunal
Antonio Crivellaro (President)
Bohuslav Klein
Hans Stuber
Legal instrumentBIT between Czech Republic and Switzerland (1990)
Further informationFull text of the decision

Statements from this decision

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The IIT definition of investment is not a self-standing concept, but refers to a more general concept provided by international law; it is common ground that to be qualified as an investment, a contract must prompt a capital contribution over a significant duration with a shared risk
An IIT's preamble is relevant for its interpretation
The IIT definition of investment is not a self-standing concept, but refers to a more general concept provided by international law; it is common ground that to be qualified as an investment, a contract must prompt a capital contribution over a significant duration with a shared risk
To qualify as an investment, a contract has to meet certain minimum requirements, such as duration, contribution and risk
The mere incorporation is insufficient to meet a "seat" requirement in an IIT; the investor has to prove additional elements
If the IIT requires the investor to prove real economic activities, the investor must substantiate its standing, e.g. by descriptive lists of contracts or witness statements by clients, banks or public officers
If an IIT imposes a requirement of having a seat and real economic activity in the host state, this requirement has the purpose of excluding "mailbox" or "paper" companies from IIT protection
The rationale of a waiting clause is to give a state the opportunity to discuss the matter with the other party; as long as the state was given this opportunity, the requirement of the waiting clause is satisfied, even if the investor did not employ the most perfect form when notifying the state
Municipal law may be relevant to the merits, but only as a factual circumstance, not as the governing law
In IIT proceedings the rules of international law cannot be disregarded
The notion of investor and investment are exclusively governed by international law
At the jurisdictional stage, a tribunal must establish whether the facts alleged by the claimant, if established, are capable of coming within those provisions of the IIT which the claimant has invoked
If no part of a claim has been successful, a tribunal may use its discretion under Article 40 UNCITRAL Rules to order the claimant to reimburse the respondent all of its costs ("costs follow the event")
An IIT's preamble is relevant for its interpretation
If no part of a claim has been successful, a tribunal may use its discretion under Article 40 UNCITRAL Rules to order the claimant to reimburse the respondent all of its costs ("costs follow the event")

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