纳税人不受过度执行权刍议

摘要

纳税人在税收法律关系中人性尊严受保障，具有人格主体的地位，与税收债权人立于平等的法律地位，并非稽征机关的支配客体，享有不受过度执行的权利。纳税人不受过度执行权的内容包括税务部门课税成本不得过高、纳税人不受过度处罚、税收调查、保全与执行不得逾越必要的界限。%　　Tax legislation should guarantee human dignity of individual taxpayers. Taxpayers are fully re-sponsible subjects and enjoy equal legal rights with tax debtor. They are not objects controlled by tax collection organs, so they should not subject to excessive executive power. By saying that, it means the tax cost of tax collection organs should not be too high; taxpayers should not get excessive punishment and tax investigation;insurance and execution should not exceed necessary limits.