With the growth of the scale of corporate data transaction, how to tax the income from data transaction between corporates has become a research focus in tax law academia, with the core focus being on the selection of appropriate tax items. Given the emerging consensus that the object of data transaction is the usage right rather than ownership, applying the tax item of “income from property transaction” to tax income from corporate data transaction would contradict the applicable logic of this tax item. Therefore, before corporate data transaction becomes normalized, catch-all provisions can be applied to evaluate the income from corporate data transaction under tax law. As corporate data transaction becomes normalized, the legislature should extract the “income from data transaction” as a tax item and adjust the tax rate for this new tax item to compensate for the user value embedded in data elements. By analyzing the types and characteristics of corporate data transaction, this paper points out that there are numerous theoretical paradoxes in generally adopting the tax item of “income from property transaction” for taxation. Therefore, a more appropriate regulatory framework should be re-established for taxing income from corporate data transaction, so as to simultaneously achieve the legitimacy and rationality of taxation on such income.