Abstract:With the further development of the Belt and Road Initiatives, cross-border investment and business activities are faced with more and complex tax disputes. The existing tax dispute resolution mechanism, especially the mutual agreement procedure mechanism, has increasingly highlighted its limitations and deficiencies. In order to further improve the efficiency and practical effect of BRI cross-border tax dispute resolution, under the background of the gradual introduction and application of tax dispute arbitration mechanism, China should establish and apply an inclusive and coordinated tax dispute arbitration mechanism in the Belt and Road region. The BRI tax dispute arbitration mechanism should be an extension and supplement of the mutual agreement procedure mechanism, and the initiation of which should be mandatory pursuant to the request of taxpayers. As regards the content shaping,such mechanism should be fully inclusive and coordinated, so as to ensure that taxation competent authorities have relevant discourse power and influence in the arbitration process. In terms of arbitration procedure model,such mechanism should generally adopt the arbitral procedure of independent opinion. With respect to tactics and methods of leading the construction of the BRI tax dispute arbitration mechanism, China should make full use of such factors as the attitude and actual acceptance of tax dispute arbitration of BRI countries and its variation tendency, thus form multilateral or bilateral arrangements that meet the pursuit of common interests with relevant countries.