competence-competence doctrine in China

The competence-competence doctrine, i.e., the arbitral tribunal has the power to decide on its own jurisdiction actually does not establised in China. According to the article 20 of the Arbitration Law of China, the jurisdiction of the Chinese Court prevails when one party goes to arbitration institution and the other party goes to court to chanllenge the validity of the arbitration agreement or arbitration clause and the opinions of the two are different.  In China, It is not the arbitral tribunal to decide the jurisdiction but the arbitration institution. Furthermore, the Chinese court can directly judge the jurisdiction. It is not consistent with the international trend of the arbitration. It causes the concern of the foreign investors.