关键词： 国际税收争议, 强制仲裁, 相互协商程序

Abstract: The Mandatory Arbitration Settlement Mechanism for International Tax Disputes is applicable to resolve international tax disputes whenever the initiating conditions are met.Compared with the traditional MAP,the result of this mechanism is more efficient,fairer and more enforceable.However,confined by its dependency on MAP,limited transparency,low taxpayer participation,and concerns about tax sovereignty,this system is not being applied on a large scale worldwide.Nevertheless,with the continuous improvement of the mechanism and the world development trend,it will play an increasingly important role in the settlement of international tax disputes.It is therefore necessary for China to introduce this mechanism to our legal system so as to grasp the initiative in international tax disputes and protect our legitimate rights and interests.The prerequisites for the application of the mechanism include:MAP,with relevant terms regulated,is set as the pre-procedure for compulsory arbitration;the scope of application of the mandatory arbitration procedure is specified;the means of arbitration awards is elaborated;the validity and enforcement of arbitration awards clarified;and more rights of the taxpayers to participate in the arbitration procedures are guaranteed.

Key words: International tax disputes, Mandatory arbitration, Mutual agreement procedure