近几年来,我们在执行税收协定中,有以下几点体会: 一、要正确认识税收协定与国内税法之间的关系。税收协定属于“条约法”范畴,它同国内法(主要指我国涉外税法)发生矛盾时,究竟是条约法服从国内注,还是国内法服从条约法。从原则上说,国际条约和国内法规具有同等的法律效力。国与国之间缔结的税收协定是对各国税法牵涉到国家之间的税收关系作出调整的 In recent years, we have realized the following points in implementing the tax treaties: First, we must correctly understand the relationship between tax treaties and domestic tax laws. Tax treaties belong to the category of “law of treaties”. When it contradicts the domestic laws (mainly referring to the foreign-related tax law of our country), whether the treaty law obeys the domestic note or the domestic law obeys the treaty law. In principle, international treaties and domestic laws and regulations have the same legal effect. The tax agreement concluded between countries is to make adjustments to the tax relations between countries involved in the tax law