Joel Dahlquist holds a doctorate in international investment and trade law from Uppsala University (2019), where he has been teaching since 2013. He is currently Counsel with Arbitration Chambers in London and New York.

• AcknowledgementsList of FiguresAbbreviationsIntroduction1 The Research Focus and Its Context1 Introduction2 The Bigger Picture3 First Focus: Domestic Courts’ Interpretation of Treaty-Based Arbitral Tribunal Jurisdiction4 Second focus: Commercial Arbitration Institutions and Treaty-Based Arbitral Tribunal Jurisdiction5 Outline2 Commercial Arbitration Rules in Investment Treaties - A Historic Background1 The (Very) Early Treaty Practice: ICSID Monopoly2 The Early Years at ICSID3 The Rise of Non-ICSID Rules4 Two Potential Explanations5 Interim Conclusion3 Domestic Courts and Lex Loci Arbitri in Treaty-Based Arbitration: Challenges of Awards1 Challenges of Investment Treaty Arbitration Awards – The Legal Framework2 Specifijic Issues Arising from Challenges in Domestic Courts3 Consequences of Challenging Treaty-Based Awards in Domestic Courts4 Investment Treaty Disputes at Commercial Arbitration Institutions1 Organization2 The Arbitration Rules3 “Jurisdictional” Considerations by Institutions4 Emergency Arbitration5 Discussion: The Scope of Institutional Decision-Making5 Conclusions1 Introduction2 Lex Loci Arbitri – the Domestic Anchor3 Internal Fragmentation4 Future Outlooks – on the Desirability of Non-ICSID Rules in Investment Arbitration5 Concluding Remarks

Joel Dahlquist holds a doctorate in international investment and trade law from Uppsala University (2019), where he has been teaching since 2013. He is currently Counsel with Arbitration Chambers in London and New York.

• AcknowledgementsList of FiguresAbbreviationsIntroduction1 The Research Focus and Its Context1 Introduction2 The Bigger Picture3 First Focus: Domestic Courts’ Interpretation of Treaty-Based Arbitral Tribunal Jurisdiction4 Second focus: Commercial Arbitration Institutions and Treaty-Based Arbitral Tribunal Jurisdiction5 Outline2 Commercial Arbitration Rules in Investment Treaties - A Historic Background1 The (Very) Early Treaty Practice: ICSID Monopoly2 The Early Years at ICSID3 The Rise of Non-ICSID Rules4 Two Potential Explanations5 Interim Conclusion3 Domestic Courts and Lex Loci Arbitri in Treaty-Based Arbitration: Challenges of Awards1 Challenges of Investment Treaty Arbitration Awards – The Legal Framework2 Specifijic Issues Arising from Challenges in Domestic Courts3 Consequences of Challenging Treaty-Based Awards in Domestic Courts4 Investment Treaty Disputes at Commercial Arbitration Institutions1 Organization2 The Arbitration Rules3 “Jurisdictional” Considerations by Institutions4 Emergency Arbitration5 Discussion: The Scope of Institutional Decision-Making5 Conclusions1 Introduction2 Lex Loci Arbitri – the Domestic Anchor3 Internal Fragmentation4 Future Outlooks – on the Desirability of Non-ICSID Rules in Investment Arbitration5 Concluding Remarks

Joel Dahlquist holds a doctorate in international investment and trade law from Uppsala University (2019), where he has been teaching since 2013. He is currently Counsel with Arbitration Chambers in London and New York.

• AcknowledgementsList of FiguresAbbreviationsIntroduction1 The Research Focus and Its Context1 Introduction2 The Bigger Picture3 First Focus: Domestic Courts’ Interpretation of Treaty-Based Arbitral Tribunal Jurisdiction4 Second focus: Commercial Arbitration Institutions and Treaty-Based Arbitral Tribunal Jurisdiction5 Outline2 Commercial Arbitration Rules in Investment Treaties - A Historic Background1 The (Very) Early Treaty Practice: ICSID Monopoly2 The Early Years at ICSID3 The Rise of Non-ICSID Rules4 Two Potential Explanations5 Interim Conclusion3 Domestic Courts and Lex Loci Arbitri in Treaty-Based Arbitration: Challenges of Awards1 Challenges of Investment Treaty Arbitration Awards – The Legal Framework2 Specifijic Issues Arising from Challenges in Domestic Courts3 Consequences of Challenging Treaty-Based Awards in Domestic Courts4 Investment Treaty Disputes at Commercial Arbitration Institutions1 Organization2 The Arbitration Rules3 “Jurisdictional” Considerations by Institutions4 Emergency Arbitration5 Discussion: The Scope of Institutional Decision-Making5 Conclusions1 Introduction2 Lex Loci Arbitri – the Domestic Anchor3 Internal Fragmentation4 Future Outlooks – on the Desirability of Non-ICSID Rules in Investment Arbitration5 Concluding Remarks