依国际仲裁法及条约法原理,税收协定争议具有可仲裁性,国际税收仲裁有其国际法依据。近年来,国际税收仲裁在制度构建、立法实践与实际运用方面都取得了较大的突破与发展。随着国际税收实践的发展,国际税收仲裁制度终将走向成熟,并为各国所普遍接受与实践。但由于国际税收实践的复杂性,国际税收仲裁的发展将是一个长期、复杂的过程。 According to the principles of international arbitration law and treaty law, disputes in tax treaties can be arbitrated, and international tax arbitration has its basis in international law. In recent years, the international tax arbitration has made great breakthrough and development in the aspects of system construction, legislative practice and practical application. With the development of international tax practice, the system of international tax arbitration will eventually mature and be generally accepted and practiced by all countries. However, due to the complexity of international tax practice, the development of international tax arbitration will be a long-term and complex process.