The reform of international investment arbitration is now in the multilateral phase and it is critical for China to evaluate its positions and options. The design of international investment arbitration should address the inherent tension between localness of substantive obligations and internationality of arbitral procedures. In theory, it is impossible for investment arbitration to pursue and realize the objectives of judicial independence, accountability and participation simultaneously and equally. In practice, traditional investment arbitration and European Union’s International Investment Court (ICS) proposals are driven by judicial independence for an impartial platform and accountability for a just forum respectively. They are also dominated by the relations between the disputing parties and relations between contracting states respectively. The U.S. 2012 Model Investment Treaty better balances the tension between judicial independence and accountability as well as the relations between economic efficiency and political feasibility. Despite failing to reconcile all three objectives, the U.S. and E.U. both chose the design plans more suitable for their comparative advantages. China’s approach to investment arbitration reform should reconcile China’s national interest and the world demand, balance the relations among contracting states, disputing parties and stakeholders, and enhance the internal stability and progressiveness. Meanwhile, China should adopt the designs most suitable for China’s comparative advantages in key provisions, such as compulsory arbitrator list, finality of first award with limited appeal, and limited participation of stakeholders in order to accommodate both national interests and international justice.