The issue of nationality of juridical persons remains unsettled long after the decision of Barcelona Traction five decades ago. In the past decade, successive International Centre for Settlement of Investment Disputes (ICSID) awards involving Cypriot corporate investors have added fuel to an already contentious and highly debated issue of nationality of juridical persons. Suffice it to say that several theories devised over a period of time have left ample room for different interpretations. A combination of criteria is used in modern BITs and FreeTrade Agreements (FTAs) for determining the nationality of companies, such as referring to the state of incorporation, management (seat) of the company, or control. It is pertinent to note that Article 25 of the ICSID Convention deliberately does not define what constitutes an investor and leaves it to the contracting parties to determine the nationality of an investor. Simply stated, the ICSID Convention does not specify what should be understood as the seat of a legal entity.