Issue 5

International Tax Regime in the Context of Digitalization: Construction, Conflicts and Solutions

CHEN Yu and NING Wenxiu

With the integration of economic globalization and digital economy, traditional international tax regime based on physical presence are facing the risk of losing effectiveness, while global base erosion and profit shifting are becoming increasingly severe. By reviewing the historical evolution of international tax regime, this article provides an in-depth analysis of the core conflicts in current multilateral regulations regarding governance philosophy, rule-making and implementation, and examines the divergent reform practices among major economies. In the BEPS 2.0 era, China faces not only the risks of profit reallocation and tax revenue loss triggered by Pillar One and the pressure of tax sovereignty transfer brought by Pillar Two, but also the dual challenge of insufficient inclusivity in multilateral rules and tax revenue loss due to outward corporate investments. It is suggested that the spirit of the global governance initiative of “upholding fairness and justice and improving global governance” should be implemented to build a unilateral system in defense of China’s national interests, deepen the alignment of domestic and international laws, strengthen China’s voice in multilateral frameworks, and ensure the competitiveness of enterprises, so as to participate in and lead the optimization and restructuring of international tax regime with systematic strategies. For details, please refer to page 20-24 of Issue 5 of Overseas Investment & Export Credits, 2025.