为了协调营业利润来源国税收管辖权和纳税人居住国的税收管辖权常设机构概念应运而生。通过对OECD范本的解读我们发现传统的常设机构概念中跨国企业必须有固定的经营场所或营业代理人。但目前互联网交易日益成熟空间对交易的限制弱化传统常设机构的概念已失去意义。跨境电商在从事经济活动中几乎不可能主动设立一个常设机构那么税收监管部门仍依照传统方式进行监管则行不通改写引号内内容避免查重

"Due to the need to coordinate the jurisdiction of the source country's taxation on business profits and the taxpayer's residence country's taxation, the concept of a permanent establishment has emerged." Based on the interpretation of the OECD model, we find that in the traditional concept of a permanent establishment, multinational enterprises must have a fixed place of business or a permanent representative. However, with the increasing maturity of internet transactions, spatial restrictions on transactions have been weakened, and the traditional concept of a permanent establishment has lost its meaning. It is almost impossible for cross-border e-commerce to establish a permanent establishment actively while engaging in economic activities. Therefore, traditional tax regulatory departments cannot continue to regulate in the same way