当前电子商务的蓬勃发展，使得各国税收和国际税收的征管和认定受到了挑战，特别是引起了财政收入的国际间不均衡转移，而兼顾各国尤其是发展中国家的利益，并且又不妨碍电子商务发展的较优方案几乎没有。两难的抉择易引起各国税收征管的扭曲，不利于业已建立的国际税制均衡， At present, the vigorous development of e-commerce has made the collection and identification of taxation and international taxation in various countries challenged. In particular, it has caused an uneven and uneven transfer of fiscal revenue while taking into consideration the interests of all countries, especially developing countries, without prejudice to the electronic There is almost no better plan for business development. The dilemma of choice can easily lead to distortions in tax collection and administration in various countries and is not conducive to the establishment of a balanced international tax system.