its focus is on solving the problems of BEPS and quite controversial tax challenges apart from BEPS. In this report, the overlapping relationship and logical relationship between BEPS and tax treaty, transfer pricing, tax rules of controlled foreign enterprises, harmful taxation system and other tax topics are recognized correctly when problems of digital economy BEPS are analyzed. It is the first time to put forward several taxation planning modes closely related to digital economy. Other tax problems apart from BEPS in the report are closely connected with the dispute for taxing power on which the developing countries and developed countries have different opinions.