International tax treaty disputes refer to disputes between the parties to an international tax treaty arising from the interpretation and application of the provisions of the tax treaty. This dispute is essentially a type of international tax dispute because international tax disputes specifically include tax disputes between countries and tax disputes between countries and multinational taxpayers.
Interstate tax disputes arise from conflicts of interest in the taxation of cross-border income and property values between countries, and most countries usually choose to sign international tax treaties to coordinate such conflicts. Therefore, interstate tax disputes are mainly manifested between countries. Disputes over the interpretation, implementation and application of the terms of mutually agreed international tax treaties, that is, international tax treaty disputes.
International tax treaty disputes are divided into direct disputes and indirect disputes. Direct disputes refer to disputes directly arising from the interpretation, implementation, and application of the terms of the tax treaty between the parties to the international tax treaty; while indirect disputes refer to indirect disputes arising from international tax disputes between transnational taxpayers and the country of origin. , Disputes between the states parties to the international tax treaty regarding the interpretation and application of the terms of the tax treaty (according to the provisions of the Model Agreement on Avoiding Double Taxation of Income and Property (hereinafter referred to as the "model") revised by the Organization for Economic Cooperation and Development, If an international tax treaty dispute arises between a transnational taxpayer and the competent authority of a Contracting State, the transnational taxpayer may submit the case to the competent authority of the country, and if the competent national authority cannot resolve the dispute unilaterally, it shall resolve the dispute with the competent authority of the Contracting State) .
The Agreement between the Chinese and Mongolian Governments on Avoiding Double Taxation of Income and Preventing Tax Evasion, signed by China and Mongolia, also made similar provisions, including mutual negotiation clauses to prevent and resolve the taxation agreement between China and Mongolia. dispute.