The Research On Profit Distribution Under New Taxing Rights In The Digital Economy

The digital economy is developing vigorously,with a wide coverage,rapid development and deep influence.It plays a key role in the reorganization of global factor resources,the reshaping of economic structure and the change of international competitive power pattern.To this end,OECD member states have begun to actively explore "unified methods" in recent years,and put forward the “double-pillar” scheme and set up the profit distribution rules under the new tax power,in order to seek international consensus,promote the reasonable distribution of multinational corporate profits in the digital economy,and ensure the fairness of international taxation.But considering the characteristics of the digital economy environment,there may be some problems in the implementation of the new tax rights and profits distribution rules proposed by OECD.Therefore,based on the background of digital economy,this paper studies the distribution of new tax rights and profits.After introducing the value creation and realization of digital economy and the concept of new taxation rights,this paper carries out theoretical analysis based on the theory of externalities,user engagement,and information asymmetry.It also analyzes the main reasons for the distribution of profits of the new taxation rights.Then,the paper analyzes the current situation of development of the global and China’s digital economy,and sorts out the unremitting efforts made by OECD in recent years on the distribution of profits,and explains the latest policy in detail,including the specific process and requirements for the new taxation rights.On the basis of analysis,this paper proposes that there are three problems in the distribution of new tax right: the determination of tax base,the determination of new connection degree and the determination of redistribution factors,and based on this,it introduces the multinational enterprise Y company to carry out the case analysis,through the case summary,the problems are caused by many factors,such as high technical requirements,inexact income source rules,single redistribution factors and operability depends on the tax authorities.Finally,in the light of the problems and reasons analyzed,it is pointed out that the distribution of new tax rights and profits in China needs the joint efforts of enterprises and the state: from the enterprise level,first,we should improve the enterprise accounting system,at the national level,we should improve the laws and regulations of cross-border taxation,strengthen the ability of tax administration by figures,and actively participate in the discussion of international tax affairs.