The quantification of future losses in cases of unlawful expropriations of non-operational projects has always been problematic. In the recent case of Tethyan Copper almost six billion dollars were awarded for the lost profits of a mining project that had no record of profitability. The fact that a significant amount of damages was awarded in this case for a project with no past production made this award highly controversial from the perspective of certainty in the quantification of damages. But this is not the only case: several other recent ICSID (International Centre for Settlement of Investment Disputes (ICSID)).tribunals have had to deal with this complex issue. When analysing this line of cases, two crucial questions emerge: what is the applicable standard of certainty regarding the quantification of future lost profits of projects with no record of production? Is a forward-looking valuation method sufficiently certain for these situations? This article will address those questions and will identify the main relevant criteria, developed in recent ICSID awards, regarding the applicability of ‘forward-looking’ methodologies, and particularly, of the DCF method, for the valuation non-operational projects.