Once the evidence has been heard, the parties make closing submissions — usually in writing, sometimes followed by oral argument. Closing submissions are often the document the tribunal keeps open while writing its award, which makes them one of the most important documents in the arbitration.
Good closing submissions follow the list of issues. For each issue, they state the party's position, identify the relevant contractual provisions and law, and refer precisely to the evidence — documents by page reference and testimony by transcript line.
They should also deal with the other side's case directly. Explaining why the opposing witnesses should not be believed, or why the opposing expert's approach is flawed, is more useful than restating your own case.
Quantum needs its own section. Tribunals need a clear path from liability to numbers: which heads of claim are established, how each is calculated and what interest and costs are claimed. Alternative calculations, in case the tribunal accepts some but not all of the case, are often helpful.
Respect the page limits and deadlines set by the tribunal. Concise, well-organised submissions are more persuasive than long ones, and they make it easier for the tribunal to adopt your reasoning in the award.