National industrial subsidies are a major irritant in international trading relations. There have been many attempts to curb the damaging effects of subsidies on the international trading order; most have met with stiff oppostion and mixed success. Today the combination of industrial subsidies and the countervailing duties intended to combat them present one of the major threats to the international trading order. is a comparative analysis of the instruments devised to regulate industrial subsidies and lessen the effects of countervailing duties.