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I. INTRODUCTION The extent to which customary law in the past and modern bilateral and multilateral investment treaties at present protect contracts concluded with States and their attributed entities has been and continues to be controversial. Some of the issues concerned relate to substantive law: - To what extent is international and treaty-based law applicable to such contracts? - To what extent is domestic law relevant for the application of international law? Others relate to procedural law: - What is the relationship between treaty-based international arbitration and other jurisdiction based on domestic law and specific contractual jurisdictional provisions? The
T.W. Wälde (Sat,) studied this question.