中国内地与台湾地区有关相互认可和执行仲裁裁决的规定,有分歧也有共性。从两岸相互认可和执行仲裁裁决的实践看,其局限性逐渐显露。为更好地运用仲裁手段调整两岸经贸关系,两岸应有意识地借鉴《纽约公约》的实体内容及内地与香港特别行政区关于相互执行仲裁裁决的安排,使两岸相互认可与执行仲裁裁决的制度趋于一致。 There are differences and commonalities between the Mainland and Taiwan in respect of the mutual recognition and enforcement of arbitral awards. From the cross-Strait mutual recognition and enforcement of arbitral awards, its limitations are gradually revealed. In order to make better use of arbitration instruments to adjust the cross-Strait economic and trade relations, the two sides of the straits should consciously learn from the substantive content of the New York Convention and arrangements between the Mainland and Hong Kong Special Administrative Region for mutual enforcement of arbitral awards so that the system of cross-Strait mutual recognition and enforcement of arbitral awards tends to Consistent.