On The Research Of The Rules Of The Permanent Establishment In The Cross-border E-commerce

With the development of science and technology and the popularity of the Internet, The trade, finance, transportation, education, advertising and other commercial areas of innovation have been promoted by the e-commerce, but the existing system of international tax law has been challenged at the same time. How to apply the rules of the permanent establishment in the cross-border e-commerce environment and to distribution the interests of international taxation has become the focus of international tax law scholars, governments, relevant international organizations.As a developing country, China is net imports country in the cross-border e-commerce. The tax base will be reduced if we continue apply the rigid application of traditional rules. For the maintenance of the income tax jurisdiction of the country of origin, we should participate in the study of how to apply the rules of the permanent establishment in the cross-border e-commerce environment.This article is based on the rules of traditional permanent establishment, to analyze the challenge by the cross-border e-commerce, introduce the theory of the problem and learn the practice of the organizations and countries. At last, to propose our solution to the problem.