Research On International Tax Dispute Resolution Under The Belt And Road

With the increasing influence of the Belt and Road initiative,the economic exchanges between the countries along the Belt and Road are getting closer and closer.Due to the huge differences in the economic level and taxation system,international tax disputes are inevitable.International tax disputes not only damage the property rights of transnational taxpayers,discourage their enthusiasm for transnational investment and trade,but also hinder the sustainable and healthy development of international economic cooperation.The importance of international tax dispute resolution is self-evident.As a traditional international tax dispute resolution method,the mutual agreement procedure is favored by all countries in the world,especially developing countries,and it is also the only dispute resolution method in China.The Belt and Road Initiative has entered its seventh year.China is playing an increasingly important role in the economic development,and has become a major source of investment for many countries.China enters the transition from a major investee to a major investor,the traditional mutual agreement procedure is no longer sufficient to effectively,promptly and fairly resolve international tax disputes.The inherent shortcomings of the mutual agreement procedure have gradually become apparent,and many countries have begun to explore new dispute resolutionmethods.With the active promotion of international organizations such as the OECD,WTO and ICC,international tax arbitration has bugun to moved to the international stage.In addition,the international arbitration of the International Court of Justice and WTO also provide a reference for the improvement of international tax dispute resolution.The OECD Multilateral Instrument and the EU Dispute Resolution Directive provide many innovative approaches to the international tax disputes resolution.This article compares the international tax dispute resolution mechanisms provided by the Multilateral Instrument and the Directive,and chooses good practices to improve the tax dispute resolution mechanisms between China and the countries along the Belt and Road.In addition to the introduction and conclusion,the main body of this article consists of four chapters:Chapter one introduces the concept of international tax disputes,the reasons,and the principles of international tax dispute resolution.Chapter two starts from the practice of international tax dispute resolution,introduces and analyzes the provisions of the mutual agreement procedure,international tax arbitration,international judicial procedures.At the same time,it summarizes the difficulties in the tax disputes resolution along the Belt and Road.Chapter three compares the OECD Multilateral Instrument and the EU Dispute Resolution Directive from the scope of application,the mutual agreement procedure,and the complementary dispute resolution procedure.Chapter four summarizes the suggestions for improving China's international tax dispute resolution mechanism.