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Indirect Expropriation - LL.M. in International Legal Studies

Indirect Expropriation - LL.M. in International Legal Studies

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No enrichment of the State required<br />

• “[ “[…] ] the h fact f that h the h expropriation i i was not<br />

directly y for the benefit of the State but for<br />

the benefit of Telecom Invest does not<br />

affect this conclusion, s<strong>in</strong>ce, as the parties<br />

agree, expropriation can exist despite<br />

there be<strong>in</strong>g no obvious benefit to the State<br />

concerned.”<br />

• Rumeli Telekom A.S. v. Kazakhstan, ICSID Case No.<br />

ARB/05/16, Award, 29 July 2008, para. 707.<br />

<strong>LL</strong>.M.<br />

IN INTERNATIONAL LEGAL STUDIES

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