As the digital economy develops rapidly, the taxation in business profits and other relevant fields suffers severe challenges, which has caught a high attention of all the global circles, and some constructive countermeasures have been put forward correspondingly. The existing multiple problems of the allocation rules of taxing rights over business profits in China, such as permanent establishments, withholding tax at source, tax assessment and formulary apportionment, location-specific advantage, tax-administrative procedure, and regional cooperation and international convention, are exposed thoroughly under the new situation. Therefore, a thorough and targeted reform in this aspect is required to resolve the problems above. We should learn from the practical experiences of the tax reform such as Pillar One of OECD, Article 12B of the Model Tax Convention of the UN, digital services tax levied by some jurisdictions overseas and so forth in this aspect actively, and combine them with the reality in China sufficiently to improve the existing rules in the relevant allocation fields of taxing rights over business profits in China further. Thus, we should take multiple measures and form a synergy to build a full set of reformative countermeasures of the allocation rules of taxing rights over business profits to better respond to changes in the situations and ensure that rules in the relevant fields in China can keep up with the times: First, in terms of substantive taxation, we should modify the relevant provisions of Law of the PRC on Enterprise Income Tax, reform permanent establishments and other existing paradigms, specify value creation and other new ideas, and improve the nexus and other rules. Besides, if necessary, we can take Article 12B of the Model Tax Convention of the UN as the correspondingly interim measure, and when the time is ripe, it can be transited to the relevant measure of Pillar One gradually. Second, in terms of foreign-related tax coordination, cooperation and response, we should maintain an innovative and open tax-related business environment, tackle actively and coordinate properly the influence on China by digital services tax and other unilateral measures, promote the reform of tax cooperation, and lead the transformation of allocation rules in the international taxation. Third, in terms of tax procedures and tax-related information administration, we should modify Law of the PRC on the Administration of Tax Collection, improve the capabilities of tax collection and administration, accelerate the digitalized construction of tax authorities, enhance the collaboration among domestic authorities concerned, strengthen the analysis and share of tax-related information, realize the globally one-stop tax registration and risk assessment, combine the data provision with the withholding tax at source from the relevant platforms as third parties, and promote international tax co-governance.