我国签署的税收协定规定以相互协商程序解决税收协定争议,但该程序存在许多缺陷如缺乏强制性、缺乏时限规定、效率低下等。现在越来越多的国家在彼此之间的税收协定中订入仲裁条款,以完善其税收协定争议解决机制。我国也有必要借鉴许多西方国家的做法,在税收协定中订立仲裁条款,以弥补相互协商程序的不足,完善中外税收协定争议解决机制。 The tax treaty signed by our country stipulates that the tax agreement should be settled through mutual consultation procedures. However, there are many flaws in the procedure such as lack of coercion, lack of time limits and inefficiencies. More and more countries are now entering into arbitration clauses in their tax treaties so as to perfect their tax treaty dispute resolution mechanism. It is also necessary for our country to draw lessons from the practices of many western countries in setting arbitration clauses in tax treaties so as to make up for the lack of mutual consultation procedures and to improve the dispute settlement mechanism for tax treaties between China and foreign countries.