In Churchill Minining Plc v Republic of Indonesia and Planet Minining Pty Ltd v Republic of Indonesia (ICSID Case No ARB/12/14 and ICSID Case No ARB/12/40), an ICSID tribunal considered whether the Republic of Indonesia had consented to arbitration under the UK-Indonesia and Australia-Indonesia bilateral investment treaties (BITs) and whether there was an investment for the purposes of the BITs.