随着各国经济交往的日益密切,国家间缔结的避免双重征税协定的数量也不断增加。尽管各国有着相似的财政目标,但当他们把缔结的税收协定适用于具体问题时,却常常产生极为不同的结果。对于这种因税收协定的解释和适用引发的争议,传统的方法是通过当事国之间的相互协商程序来解决, As the economic exchanges between various countries are getting closer, the number of double taxation agreements for avoiding double taxation concluded between countries has also been on the rise. Although countries have similar financial goals, they often produce very different results when they apply the tax treaties concluded to specific issues. The traditional approach to this controversy over the interpretation and application of tax treaties is resolved through the process of mutual agreement between the parties,