Implementing Substance Over Form: A Novel Metric for Taxing E-commerce to Address Deterritorialization

Abstract

Against the backdrop of e-commerce restructuring consumption patterns, last-mile delivery stations have substantially fulfilled the function of community retail distribution. However, the current tax system only levies a low labor service tax on delivery fees, resulting in a tax contribution from the massive circulating goods value that is significantly lower than that of retail supermarkets of equivalent scale. This disparity not only triggers local tax base erosion but also fosters unfair competition. Based on the "substance over form" principle, this paper proposes a tax rate calculation method using "delivery fee plus insurance premium" as the base, corrected through "goods value conversion." This method aims to align the substantive tax burden of e-commerce with that of community retail at the terminal stage, effectively internalizing the high negative externalities of delivery stations through fiscal instruments, addressing E-commerce Deterritorialization.