当前,以仲裁方式解决两岸经贸纠纷已成为法律界的共识。但两岸现行相互认可与执行民事仲裁裁决的法律依据,却存在简单套用认可与执行法院判决的规定,申请认可时效违背仲裁效率原则,潜藏公共秩序保留原则滥用可能和可以认可与执行的仲裁裁决范围不明等问题。为了消除上述问题,海峡两岸可采取完善各自单边立法、签订两岸专项协议等对策。 At present, solving the cross-Strait economic and trade disputes by arbitration has become the consensus of the legal community. However, the existing legal basis for cross-Strait mutual recognition and enforcement of civil arbitral awards lies in the simple application of the rules of recognition and enforcement of court judgments, the non-compliance with the principle of arbitration efficiency, the potential abuse of latent public order reservation and the scope of arbitral awards that can be recognized and enforced Unknown issues. In order to eliminate the above-mentioned problems, both sides of the Taiwan Strait can take measures to improve their respective unilateral legislations and sign special cross-Strait agreements.