By the time the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) entered into force, there had been numerous bilateral and multilateral agreements between the parties regarding its rules on dispute settlement. However, the WTO dispute settlement system currently remains the most requested. The present article provides a comparative analysis of the procedures of dispute settlement under the CPTPP, the WTO DSU, and some RTAs. Among the novelties of the CPTPP mechanism compared to the WTO DSU are that it extends its scope to measures not yet introduced, offers more transparency, including the use of electronic means of communication, simplifies access for third parties, and provides financial compensation as a temporary remedy. Although the authors conclude that many of the CPTPP provisions repeat those of the WTO DSU and other RTAs between the CPTPP partners, there may be a desire to test the CPTPP mechanism in practice due to crises of the WTO Appellate Body.

The calls for reform of investment treaty regime are neither novel nor entirely unexpected. And the need for that reform has recently reached its pitiful nadir where the UNCITRAL Working Group III gathered for its first meeting in Vienna back in November-December 2017 to discuss states’ concerns about investor-state dispute settlement. States’ concerns about the reform have been repeatedly referred to in recent publications, but international scholars have not yet discussed Russia's stance in detail. In the following an attempt has been made to fill the gap in literature by introducing the Russian position which contrasts nicely with Canada or the EU. Why is this important? Russia is a significant state in the UNCITRAL Working Group III and any slight shifts in its approach in the UNCITRAL reforms are closely watched. It is the right time to provide an analytical framework for understanding the Russian position in these reform dynamics.