Although China has been an active ‘treaty-maker’ in the realm of international investment arbitration as evidenced by its more than 120 bilateral investment treaties, the utility of these BITs has been very limited. Substantive standards such as expropriation and compensation have never been comprehensively tested with respect to these BITs. This article scrutinizes the concept of expropriation by reference to Chinese investment treaty jurisprudence, in particular, the final award of Tza Yap Shum v. The Republic of Peru and China’s free trade agreement with Peru, the only Chinese BIT-related ICSID case. This article critically examines, in a comparative context, the treaty interpretation methodologies employed by the tribunal in interpreting expropriation under the China-Peru BIT, which is one of the earlier Chinese BITs. A thorough study of this subject is of great significance to interpreting the terms of indirect expropriation and compensation in Chinese BITs, thereby offering more concrete foreign investment protections based on investment treaties.

Today, as individuals show their social identities and reflect their being as the members of society with a culture, an art style and communication function are stood out in fashion photographs. Accordingly, the meanings of images into text are expanded in its interpretative width through the acceptor's various terms. This researcher looked into four theories of both positions on the textuality of language and image, and considered the point of discussion on image of each theory through modern fashion photographs. First, the theory which divides language and image as auditory and visual recognitions in the textuality of language and image is limited from the view it focuses on only one side without considering the ambivalent elements of each field. For the textuality in modern fashion photographs, the observer attempts to turn it into text to give meaning to it as the recognition through five senses conforming to the acceptor's condition. Second, the theory dividing language and image into the text of time properties and spacial properties has limitation in the text, for acceptor's experience of the object appears as the structured form in time and space rather than being defined as two things like time and space. Third, the theory classifying the language and image text into conventional taste and natural taste has limitation from the view that image text is hardly an object of consistent classification in ease of recognition by the code accepted in society. Thus, this can't be fundamental approach for the understanding of the text of decoding trend represented in modern fashion photographs. Fourth, accordingly, this researcher focussed on contextual and arbitrary text of fashion photographs through the theory of Nelson Goodman which discusses image text through the differences in textuality. Basic mechanism of perceiving and recognizing and distinguish image is closely related to habit and custom like language. So, each acceptor perceives the image as a text through arbitrary interpretation obtained by individual, empirical, historical, and educational viewpoints. The textuality of modern fashion photographs aims to widen the range of diverse knowledge and understanding, transcending the regulations of simple function of existing fashion photographs. Consequently, this researcher puts forward the opinion of consistent and diverse follow-up studies on instilling meaning into fashion photographs for the understanding de-regulatory and de-constructive through various senses by avoiding only one sense-dependent fixed and regulatory properties of it