仲裁作为解决国际税收争端的新方式,日益受到国际社会重视,经合组织和美国等纷纷在税收协定或其范本中引入仲裁条款。鉴于传统的相互协商程序在解决税收争端时仍保持较高的效率,当务之急是完善和改进中外税收协定中的相互协商程序,然后逐步在转移定价等特定事项上引入自愿性仲裁程序,以兼顾国家税收主权和纳税人权利。 Arbitration, as a new way to solve international tax disputes, has drawn more and more attention from the international community. Both the OECD and the United States have introduced arbitration provisions in their tax treaties or their models. In view of the fact that the traditional procedures for mutual consultation have remained relatively efficient in resolving tax disputes, the top priority is to improve and improve the process of mutual agreement in tax treaties between China and foreign countries, and then gradually introduce voluntary arbitration procedures on specific issues such as transfer pricing so as to take account of the differences between countries Tax sovereignty and taxpayer rights.