Research On Improving The Mutual Agreement Procedure In Tax Treaty

As countries become more economically connected,the number of double taxation agreements concluded is also increasing.Although countries have similar fiscal targets,when they apply for tax treaties in practice,they often produce very different results,triggering international tax disputes.The solution to these traditional international tax disputes is the process of mutual agreement and certain domestic legal procedures.However,the deficiencies of MAP have become increasingly prominent,and various countries and international organizations are constantly striving to improve the negotiation process between the two parties,especially the Organization for Economic Cooperation and Development.In addition,with the development of economic globalization,China has become an important member of the world's economic activities,and bilateral tax treaties with foreign countries have also increased significantly.Of course,international tax disputes are also increasing,but China's MAP is still in the early stages of development and often cannot meet the needs of existing practices.Therefore,based on the tax treaty model of the Organization for Economic Co-operation and Development,the article proposes to improve China's MAP by comparing and analyzing the OECD tax treaty model with the US MAP and combining China's national conditions.In addition to the introduction and conclusion,the main body of the article isthree chapters:The first chapter is about the overview of MAP,introduces the concept of MAP,and discusses the basic content of the program and the current dilemma,and analyzes and compares the international regulations on MAP.The second chapter begins with the OECD's latest BEPS Action Plan 14 and analyzes its specific provisions for MAP.Secondly,it introduces the regulations and practices of the MAP mechanism in the United States.Finally,it compares the two and summarizes the international experience of MAP perfection.The third chapter analyzes the rules and practices of MAP from China,and combines the “Implementation Measures for Mutual Consultation Procedures of Tax Agreements” and related cases to make recommendations for improving China MAP.