The question of the degree of
overlap between the substantive provisions generally found in investment
treaties and EU law was left unanswered by Case C-284/16 Slowakische
Republik v. Achmea B.V. From a practical perspective, investors are left in doubt:
assuming that they cannot rely on a dispute resolution clause such as that at
issue in Achmea, does EU law offer substantially identical protection? The
recent decision of Case C-235/17 Commission v. Hungary may go some way towards reassuring investors EU
law may provide materially similar protections to some of the substantive
protections ordinarily found in bits. This note (I) provides a summary of the
views of the Commission (and respondent Member States) on the issue of the
overlap between substantive protections generally found in investment treaties
and EU law, (II) considers the Opinion of Advocate General Wathelet on the same
issue and (III) considers the decision of Commission v. Hungary.