Conclusions
This case suggests a significant adoption of the 'wide' MFN approach, running against the grain of recent MFN awards which have reduced the scope of MFN protection(eg, Salini v. Jordan and Plama Consortium v. Bulgaria). The decision will be of particular interest to Chinese investors and foreign investors in China, whose most recent BITs (including the China–Germany BIT of 2005), contain much broader dispute settlement provisions than Chinese BITs which came into force prior to that date. China has entered into BITs with more than one hundred States, so the reliance on MFN clauses is an area of huge potential significance.