利用仲裁解决中外税收协定争议问题探讨（Discussion on disputes between China and foreign countries in settlement of tax treaties by arbitration）.docVIP

利用仲裁解决中外税收协定争议问题探讨（Discussion on disputes between China and foreign countries in settlement of tax treaties by arbitration） Discussion on disputes between China and foreign countries in settlement of tax treaties by arbitration Abstract: because of the traditional mutual consultative procedure, there are many problems in the settlement of the dispute over the international tax treaties More and more countries are seeking to settle disputes over the tax treaties between China and foreign countries Arbitration clause. The necessity and feasibility of using arbitration to settle disputes between Chinese and foreign tax treaties are investigated Some concrete proposals are put forward to solve the disputes between China and foreign countries in terms of arbitration agreement. Key words: Sino foreign tax treaty dispute; mutual consultation procedure; arbitration 1, the necessity of using arbitration to resolve disputes between China and foreign tax treaties With the development of Chinas opening to the outside world and contacts, especially after Chinas accession to the WTO, China and foreign countries have concluded The number of tax treaties is on the increase. At present, our country has signed income with 87 countries and regions A tax agreement to avoid double taxation, including almost all developed countries and most of them In the developing countries, the mainland has also signed with Hongkong and Macao the avoidance of double taxation arrangements, including 77 agreements and The 2 arrangements have come into force. It can be foreseen that with the acceleration of the process of economic globalization, Chinas reform will be carried out The number of Sino foreign tax treaties to be concluded will continue to increase. With the tax With the increase of agreement, the emergence of tax disputes at home and abroad has gradually increased. The American satellite company tax code is received The example of this case is about the exercise of the right to levy Taxation