In recent years,digital economy has sprung up all over the world,and has deeply radiated to many levels of global economic development.With its unique internet development model,it has shaped a new pattern of international economic development,and also set off a wave of reallocation of tax jurisdiction and substantive reform of international tax system all over the world.Due to the lack of corresponding tax rules,how to deal with the international tax challenges brought by economic digitization is still the focus of attention and discussion in the international community.To this end,OECD proposed in 2019 to establish a "unified method" on the new connection degree and profit distribution rules,as a consensus method to divide the new international tax power and profit.OECD "unified method" is based on the three proposals of "user participation","marketing intangible assets" and"significant economic existence",and takes the new taxation right rules and new profit distribution rules as the two logical emphases.It creates a new scheme of defining the tax connection degree and distributing tax profits for non entity existence by formula distribution method.This paper focuses on the rationality of the tax governance plan to deal with economic digitization under the current OECD "unified approach" progress,and gives the possible options and solutions to the practical problems faced by OECD "unified approach" in practice.As a temporary reform plan for digital economy taxation,OECD "unified approach" can effectively avoid the loss of huge amount of digital economy tax in market countries by establishing a new connection between business and tax under the mode of no entity and no intermediary transaction,especially for those developing countries.In addition to the technical problems such as the contradiction between the old and new rules and the risk of double taxation,the final implementation and implementation efficiency of the OECD "unified approach" are also affected by the interest game at the political level.To solve these problems,international tax rules,tax treaties and domestic tax laws need to be designed and followed up,and countries need to carry out multilateral cooperation and political measurement on the premise of reaching a general consensus.Under the trend of highly digitized cross-border trade business model and increasingly fierce competition among countries for tax rights,China should also make forward-looking responses to the OECD "unified approach" as a typical international tax reform plan,including revising the recognition standard of permanent establishment,levying withholding income tax on non resident enterprises with logarithmic economy,accelerating the research process of international cooperation and tax treaties,and improving the quality of taxation In order to improve the ability and level of tax collection and management,We should improve the ability of tax control of digital economy enterprises in China,and strive for and safeguard China’s tax sovereignty in the international scope. |