Dr. Michael de Boeck:

Let me address the first question. As we said a little earlier in the meeting, the important rulings of the ECJ on Achmea, Komstroy and PL Holdings are all applicable to international investment awards that were rendered in an intra-EU setting. They are very important and relevant to EU law.

However, as I set out earlier, it is not binding on international investment tribunals. As a consequence of the autonomy of EU law and international law, investment arbitration tribunals will very likely continue to ignore the judgment of the Court of Justice regarding the incompatibility of intra-EU investment arbitration simply because it does not bind them.