Abstract
The United States concluded in 2015, the Trans-Pacific Partnership (TPP) agreement with 11 other countries and the European Union (EU) concluded a revised version of the Comprehensive Economic Trade Agreement (CETA) with Canada in 2016. The provisions on investor – state dispute settlement (ISDS) of the two agreements could not be more different. While the TPP sticks to the traditional system of investor – state arbitration, CETA now contains a two-layered court system with pre-elected tribunal members. The present contribution seeks to analyse the convergences and differences between the two first concluded mega-regionals in greater detail with a special focus on the CETA court system. It asks, to what extent CETA and TPP address current criticisms on ISDS? What do their approaches mean for the international investment governance? And more specifically for the ongoing negotiations on the Transatlantic Trade and Investment Partnership agreement (TTIP) between the EU and the United States?
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