11 Another(less ideal) alternative can be drawn from WTO experience, where developed countries regularly contribute to the Global Trust Fund and the Aid for Trade fund.18 A central developing country defense fund could be used to finance the nomination of independent panel members or expert witnesses. A degressive percentage of the amounts in question(i.e., a smaller percentage for larger amounts) could be posted as a mandatory contribution to this fund by the levying jurisdiction. Alternatively, at the initial stage, the fund could include contributions from all countries participating in the mandatory binding resolution mechanisms proportionate to GDP. Some G-24 countries have national agencies dedicated to the legal defense of the country, especially in cases in which the country has faced investment arbitration claims. These agencies usually have ample resources that can be used in practice to fund legal and expert witness expenses. Finally, G-24 countries should find a balance between the possibilities of appealing against an unfair decision and limiting the scenarios for appeals before the determination panel, which are likely to increase the costs of the mechanism. A simple majority decision could be enough at the Review Panel level, and the Determination Panel need only meet if there is a disagreement in the application of a principle. In all cases, the reasons for establishing a Determination Panel must be clearly set out in the rules. Cost-related strategies for G-24 countries ★ Propose virtual meetings and case accumulation for cost efficiency. ★ Propose common funding of total costs split proportionate to the GDP of participating jurisdictions in each mechanism. ★ Propose ceilings to the costs borne by developing countries expressed as a percentage of GDP. ★ Propose the creation of a developing country fund to be financed by developed countries and by a percentage of the amounts in discussion for each panel, to be contributed by the levying country. ★ Take advantage of national legal defense agencies to use the resources to retain legal or accounting advice, or to bring an expert witness to the procedure. ★ Demand clarity in the rules that allow for a Determination Panel or any other mechanism for appeals. Panel composition Although the preliminary Review Panel for Amount A will decide on the proposal of the UPE jurisdiction, it is less likely that developing countries will bear an economic loss as a result of the decision of this panel. Contentious issues for the Review Panel to decide are limited to the sourcing rules and the determination of which entity within the group is responsible for the residual profits earned by the group. These issues may affect G-24 countries in the allocation of Amount A and in the alleviation of double taxation. However, in principle, it is possible that the UPE proposal will be acceptable to all 18 See https://www.wto.org/english/tratop_e/devel_e/teccop_e/financing_trta_e.htm.(last accessed on 21.2.2022)