As the digital economy gradually becomes the economy itself, the traditional international tax jurisdic? tion rules and the digital economy have been facing the institutional adaptation dilemma. The mismatch between the value creation place and the profit tax place has been serious, and the traditional tax base has been seriously eroded. However, after analyzing the value creation of global economic components, it is found that the basic logic elements of value creation of traditional economy and digital economy have not changed significantly. Therefore, the existing national practice plans can be divided based on producers, users and intangible assets as different value creation fulcrum, so as to better observe the adjustment path of tax jurisdiction rules of the source country. After the theoretical induction, analysis and comparison of taxable existence and profit distribution, the marketing intangible assets scheme shows better adaptability to remodel the rules of origin, which is embodied in the universality of its application scope and the simplicity of surplus profit segmentation. Based on China’s dual tax status and the economic reality of“self-sufficiency”, promoting the marketing intangible assets scheme step by step is the guidance and enlightenment of value creation principle for China to deal with the change of in? ternational jurisdiction rules on the basis of the international and domestic dual circulation pattern.