一、加入仲裁解决方法的动因相互协商程序(MAP)一直是OECD范本及其注释中解决争议的唯一方法。相互协商程序在过去运转良好,但跨境争议的数量和所涉案件的复杂性大为增加,由于MAP并不要求缔约国一定要达成最终协议,缔约国只是有义务要达成一致,所以经常会留有一些未解决的问题,从而阻碍了MAP的有效运行。也正是因为这个原因,纳税人就会对利用相互协商程序解决问题丧失信心,税务部门也没有足够动力尽全力解决争议。因此,必须 I. Motivation for joining the arbitration settlement The mutual agreement (MAP) has been the only way to resolve disputes in the OECD Model and its notes. The process of mutual agreement has worked well in the past, but the number of cross-border disputes and the complexity of the cases involved have greatly increased. Since MAP does not require contracting parties to conclude a definitive agreement, and contracting parties are only obliged to reach an agreement, they are often left behind Some unresolved issues hinder the effective operation of MAP. It is precisely for this reason that taxpayers will lose confidence in resolving problems by using mutual consultation procedures, and the tax authorities have not given enough incentive to do their utmost to resolve the dispute. Therefore, must