The Law and Practice of International
Courts and Tribunals 16 (2017) 108–138
brill.com/lape
© koninklijke brill nv, leiden, 2�17 | doi 10.1163/15718034-12341344
ICSID Jurisdiction with Regard to State-Owned
Enterprises – Moving Toward an Approach Based
on General International Law
Giulio Alvaro Cortesi
Ph.D. Candidate, University of Padua and Paris I Panthéon – Sorbonne
cortesigiulio@gmail.com
Abstract
The decision of the ad hoc Committee in the case Tulip Real Estate v. Turkey of 2015 rep-
resents a new development in the methods applied by ICSID tribunals to ascertain their
own jurisdiction when the acts giving rise to the investor’s claim have been undertaken
by a State-owned entity. Indeed, prior to this case, different views and trends had arisen
over the years: some tribunals have addressed this matter by narrowing their field of
analysis to the formal requirements of the claim, while others have focused on the issue
of implicit designation. Lastly, there has been a growing trend, starting in 2009 with the
case Toto Costruzioni v. Lebanon, where arbitrators have applied the rules on attribution
at the jurisdictional stage. This last group of cases suggests that those arbitrators were
developing an approach closer to that of general international law. The Tulip Real Estate
v. Turkey Committee was the first annulment panel to comment on this latest develop-
ment, although they commented without expressing much enthusiasm for it. The pres-
ent article will focus on the issue of establishing an ICSID tribunal’s jurisdiction when a
State entity is involved in the proceedings, in order to cast some light on the rules that
a tribunal should apply when deciding whether a dispute between the foreign investor
and a State entity falls within its remit.
Keywords
State-owned enterprise – attribution – designation – IC SID jurisdiction
* The author would like to thank Professor Andrea Gattini and Professor Hervé Ascensio for
providing guidance, inspiration and support.