The Current Status, Issues, and Prospects of China's International Tax Dispute Resolution Mechanism.

China attaches great importance to and actively participates in the implementation of the Base Erosion and Profit Shifting Action Plan, revising bilateral tax treaties with other countries multiple times to proactively address tax dispute cases. However, since 2016, there has been a significant increase in new tax dispute cases, highlighting the urgent need for China to enhance its capacity in resolving international tax disputes and establish a comprehensive and efficient dispute resolution system. This article analyses the current operation of China's international tax dispute resolution mechanism, identifying issues such as the need for optimisation of bilateral tax treaties, inefficiencies in the operation of the mutual agreement procedure, and inadequate taxpayer participation. Additionally, the necessity and feasibility of introducing a mandatory arbitration mechanism in bilateral tax treaties are addressed, providing specific design recommendations for such mechanism. Furthermore, alternative tax dispute resolution mechanisms are also explored. [ABSTRACT FROM AUTHOR]