No matter how perfect the tax system design is and how complicated the tax law rules are, tax evasion, tax avoidance, and tax planning are always facts that cannot be eliminated in the practice of tax law, and are also problems that the tax authorities of various countries have to face. Whether tax collection is based on form or substance has always been a controversial topic in the field of tax law. The origin and development of the principle of substantial taxation have a very similar path in continental legal system and Anglo-American legal system. In continental legal system countries, whether it is the economic observation method originated in Germany or the principle of substantive taxation principle upgraded by Japanese scholars, the establishment of the two in tax legislation was both originally derived from the need for anti-tax avoidance, both the result of the revision of tax law at that time to ensure national fiscal revenue. Judging from the evolution of the principle of substantive taxation in the Anglo-American legal system, the principle of substantive taxation has gone through the process of being denied to being allowed. Since the Anglo-American legal system is mainly based on case law, the substantive taxation principle is mainly established through the judgment of the court, which is obviously different from the continental legal system to determine the substantive taxation principle through tax legislation. From the background, anti-avoidance is the direct motivation or initial reason for the emergence or establishment of the substantive taxation principle in the tax legislation or tax judicial practice of the two legal systems. Legal substantialism and economic substantialism are applicable to different occasions in tax law. Legal substantialism should be applied in cases where the form and substance of "legal relationship" are inconsistent, while economic substantialism should be applied in cases where the legal form and the economic substance are inconsistent. Only by combining legal substantialism with economic substantialism, can we deal with various complicated tax issues and make the economy of tax coincide with the authority of law. Although the substantive taxation principle has different appellations in the two legal systems, and there are many differences between the theoretical and practical circles on the connotation and functional positioning of the substantive taxation principle, it can be found from many debates on the substantive taxation principle that the substantive taxation principle has not been completely denied, but is a technical and instrumental principle to realize the principle of tax fairness and the principle of capacity based taxation in the tax law, and an important supplement to the principle of taxation legality. Its purpose is to require taxpayers to pay taxes according to their substantial tax bearing capacity, and finally realize the fair distribution of tax burden. It should be noted that the principle of substantive taxation applies to all links of the operation of tax law, but not to all fields of all links of the operation of tax law.