经济全球化的发展,带动了国家间税收合作的发展,国际税收合作的发展反过来又促进了全球经济的繁荣,同时也带来了国际税收争议的频繁出现,阻碍了经济的发展。本文指出为此国际社会致力于解决国际税收争议,尤其是OECD国家创立的OECD模式,即相互协商程序模式,在国际税收协调方面的成就颇为明显。但其不足之处也是显而易见的,从博弈论的角度能够透彻分析阻碍其有效性的深层因素,并提出完善建议。 The development of economic globalization has led to the development of tax cooperation among countries. The development of international tax cooperation has in turn promoted the global economic prosperity. At the same time, it has brought frequent international tax disputes and hindered economic development. This article points out that for this purpose, the international community is committed to resolving international tax disputes, especially the OECD model established by the OECD countries, that is, the mode of mutual agreement and negotiation, and its achievements in international tax coordination are quite obvious. However, its shortcomings are obvious. From the perspective of game theory, it can thoroughly analyze the deep factors that hinder its effectiveness and put forward some suggestions.