The digital economy has gradually become a new driving force and an important source of tax revenue for the economic development of countries around the world. Due to the unique virtuality of the digital economy and the cross-regional nature of the value chain, the physical presence of permanent establishments cannot serve as the connecting factor for digital economy taxation, resulting in a mismatch between the location of value creation and the location of profit taxation in the digital economy relationship. In response to the international tax challenges brought about by economic digitization, the OECD has proposed a “two-pillar” plan to reform international tax rules. However, it still faces issues such as the complexity of multilateralism in international taxation and the technical difficulty of rule transformation, making it difficult to ensure that multinational enterprises pay taxes fairly and the tax rights of countries. China needs to strengthen its voice in the formulation of international tax rules, reasonably set the scope of collection, and minimize the impact of international tax changes on the economy.