Rajah & Tann Singapore has contributed an article titled “Accountability and Accommodation: The Singapore Courts and Intra-EU Investor-State Arbitration” in the June 2026 issue of the ThoughtLeaders4 Disputes Magazine.
Singapore is one of the world’s most popular seats of arbitration, and the Singapore courts have had occasion to consider the interplay between the enforcement of arbitral awards in Singapore, and European Union (“EU“) law. Authored by Partner Matthew Koh from the International Arbitration Practice, the article examines how Singapore courts have analysed the issue of validity or permissibility of intra-EU investor-state arbitration in two recent decisions, and considers their implications for the global system of investor-state dispute settlement (“ISDS“).
The article highlights the measured and balanced approach adopted by the Singapore courts between respect for the EU courts and the interests of investors. In striking this balance, the Singapore courts have closely examined the wording and context of the relevant treaties, and applied international law carefully. Together, these two decisions illustrate how courts outside the EU may approach the interaction between the global ISDS system and intra-EU investor-state disputes.
The article notes that the groundwork laid in these decisions positions the Singapore courts well to deal with similar disputes in future, particularly given Singapore’s status as a financial centre and leading arbitral seat.
The full article is available here (pages 23-26).
Find out more about our International Arbitration Practice here.
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