Abstract: The international tax reform of the digital economy is in full swing, and the OECD has designed a“two-pillar”basic plan, trying to establish market state taxation rights and a global minimum tax system to improve the international taxation order. In response to the above-mentioned reforms, based on the analytical framework of the New-market Public-finance Theory under exploration, this article develops innovative cognitions from the following three aspects: the first is to form a concept of platform market, so as to innovate the explanation of both the platform entities of the new digital economy market and the significance of the tax nexus to such entities, and the market mechanism of the new digital economy platform as well as its characteristics of tax laws and regulations; the second is to form a concept of comparable governments, so as to explore the rectification of the productive role of governments and the proof of the legitimacy of taxation rights, the restoration of the panorama of the comparability of cross-border transactions, and the calculation of comparable government tax bases; the third is to specify the concept of income control rights, so as to separately analyze the tax benefit games between multinational corporations and governments in the OECD reform plan, and the competitions of industrial patterns between countries and the industrial groups in the digital economy. Finally, based on the above logic and basic national conditions, this article proposes some initial policy responses with an emphasis that China should systematically design policies to cope with the global competition and cooperation against the anti-tax avoidance, the global big cycle of digital and industrial economies, and the economic development of the backward regions and the emerging industries from the three levels of security, fairness and development of the national tax bases.

Key words: OECD, digital economy, international tax reform, new-market public-finance, platform market