The paper advances the paradoxical thesis that international investment law is developing towards a multilateral system of investment protection on the basis of bilateral treaties. Despite the infinite fragmentation of substantive investment law, coupled with arbitration as a decentralized...

The interaction between private and public in international investment law and investor-state arbitration raises the question of who (arbitral tribunals, home states, host states, investors, or international organisations active in the field of foreign investment) should be responsible for...