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Pope & Talbot v. Canada

Type of decisionAward on the merits of phase 2
Date of decision10 April 2001
Tribunal
John Murray Dervaird (President)
Benjamin J. Greenberg
Murray J. Belman
Legal instrumentNorth American Free Trade Agreement
Related decision(s)
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Statements from this decision

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Relationship between NAFTA and other treaties of the same parties
Relationship between NAFTA and other treaties of the same parties
The fairness elements in Article 1105 NAFTA are in addition to to the requirements of international law and must be applied without any threshold limitation of the conduct being “egregious”, “outrageous”, “shocking ”, or “extraordinary”
It is not for a tribunal to decide the validity of a state’s choice of action, so long as that choice does not rise to a denial of fair and equitable treatment
On determining the meaning of the term “like circumstances”, a tribunal must consider the facts, the legal context, and the state measures of the given case
Article 1102 (2) NAFTA applies to single investments; the claimant does not need to demonstrate that there are other similarly situated foreign investments or that there is more than one domestically owned investment in a similar situation
The elements of a measure causing a discrimination of the foreign investor cannot be used to deny the existence of “like circumstances” unless there is a reasonable nexus to a rational, non-discriminatory government policy
Within the scope of Article 1102 NAFTA, there is no reason to treat de facto and de jure discrimination differently; a finding of a disproportional disadvantage caused by the measure is not necessary in cases of de facto discrimination
Article 1102 NAFTA requires a two-part test: first, a comparison to domestic investments in the same business or economic sector; second, an examination whether there is a reasonable nexus to rational government policies not discriminating against foreigners and not undermining the objectives of NAFTA
Relationship between NAFTA and other treaties of the same parties
Articles 1102(1) and (2) and Article 1102 (3) are substantially identical, except for the limitations to states and provinces
In its assessment of the “like circumstances”, the tribunal must to consider the facts, the legal context, and the state measures of the given case
Article 1102 (2) NAFTA applies to single investments; the claimant does not need to demonstrate that there are other similarly situated foreign investments or that there is more than one similarly situated domestically owned investment
Article 1102 NAFTA requires a two-part test: first, a comparison to domestic investments in the same business or economic sector; second, an examination of whether there is a reasonable nexus to rational government policies not discriminating against foreigners and not undermining the objectives of NAFTA
The elements of a measure causing a discrimination of the foreign investor cannot be used to deny the existence of “like circumstances” unless there is a reasonable nexus to a rational, non-discriminatory government policy
Within the scope of Article 1102 NAFTA, there is no reason to treat de facto and de jure discrimination differently; a finding of a disproportional disadvantage caused by the measure is not necessary in cases of de facto discrimination
Article 1102 NAFTA requires a two-part test: first, a comparison to domestic investments in the same business or economic sector; second, an examination of whether there is a reasonable nexus to rational government policies not discriminating against foreigners and not undermining the objectives of NAFTA
The fairness elements in Article 1105 NAFTA are additive to the requirements of international law and must be applied without any threshold limitation of the conduct being “egregious”, “outrageous”, “shocking”, or “extraordinary”
It is not for a tribunal to decide the validity of a state’s choice of action, so long as that choice does not rise to a denial of fair and equitable treatment

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