一、税收立法过程中的程序正义没有一个科学、合理的税收法律体系,税收法治就无从谈起。我国税收法制的现状是,实体法领域法律少、条例多,税收领域法律层次偏低。税收实践中一些级别较低的、不成熟的、随意性较大的税收文件,被税务机关作为关键性的执法依据加以适用,造成税收征管程序法律规范的实际适用效用大打折扣。这一现象表明,目前我国税法级次结构不合理,立法权利 First, the procedural justice in the process of tax legislation Without a scientific and reasonable tax legal system, the rule of law of tax can not be mentioned. The status quo of our country’s taxation legal system is that there are few laws and regulations in the field of substantive law and many laws and regulations are low in the field of taxation. Some low-level, immature and arbitrary tax documents in the practice of taxation are subject to application by the tax authorities as the key law enforcement basis, resulting in a reduction in the practical application of the legal norms of tax collection procedures. This phenomenon shows that, at present, China’s tax hierarchy is not reasonable, legislative rights