Abstract
In economic globalization, China plays an increasingly important role, and Chinese enterprises are speeding up the pace of going global. In this process, “going out” enterprises face prominent tax risks. Some countries adopt arbitration to settle international tax disputes, but China does not. However, the widely used MAP has many disadvantages, and tax disputes cannot be solved efficiently. To deal with this, the Pillar 1 Blueprint calls for mandatory binding arbitration of disputes over Amount A, which can be seen as a future trend. This paper suggests that China should adopt temporary means of tax arbitration and enhance taxpayers’ participation in the arbitration procedure. In addition, setting up tax dispute prevention measures to protect the interests of multinational enterprises to a greater extent.
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