现行税制建立在有形交易的基础上，以常设机构、居住地等为依托将纳税人的活动与纳税义务联系起来。电子商务的出现极大地削弱了现行税制存在的基础。相比较而言，直接电子商务对于现行税制的冲击更为明显。电子商务交易实体和过程都是无形的,因此纳税义务人难以确定；征税对象 The current tax system is based on the physical transaction and links taxpayers’ activities with tax liability based on permanent establishment, place of residence, etc. The emergence of e-commerce has greatly weakened the foundation of the existing tax system. In contrast, the impact of direct e-commerce on the current tax system is even more pronounced. E-commerce transaction entities and processes are intangible, so the taxpayer is difficult to determine; tax object