Gaining access to foreign technology is a primary determinant of economic development for developing countries, and it also plays a vital role in addressing a variety of public needs.1 For such reasons, encouraging and managing international technology transfer has become a significant governance issue.2 It has been recognized that, in addition to the World Trade Organization (WTO) legal mechanism, the national foreign investment mechanism and international investment agreements (IIAs) also regulate technology transfer through the ‘establishment rules’ and performance requirement prohibitions (PRPs).3 However, these competing and overlapping systems raise concerns about policy coherence between IIAs and parties’ policy options to manage their technology transfer obligations.4 In recent years, countries such as the USA and the European Union (EU) have repeatedly accused China of forcing technology transfer.5 For example, the USA launched a ‘301’ investigation against China and sued China in the WTO forum.6 The 301 Report issued by the USA alleged that China had imposed FTT by imposing ownership and administrative restrictions on American enterprises.7 In response to these accusations, China began a new round of reforms to improve the foreign investment regime governing technology transfer and signed some high-level investment agreements.8 However, these efforts have not been entirely successful in alleviating the misunderstandings of foreign investors over China’s technology transfer policies. These disputes are primarily attributed to the unclear boundaries for mandatory technology transfer in international investment.