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随着我国对外开放政策的实施,涉外税务工作有很大的发展,在涉外税收中发生的争议与诉讼也逐渐增多。因此,涉外税务诉讼的问题也成为研究的课题。对此,我想结合《中华人民共和国行政诉讼法》的颁布实施谈点浅见。一、涉外税务诉讼及其特点《中华人民共和国行政诉讼法》第二条规定:“公民、法人或者其他组织认为行政机关和行政机关工作人员的具体行政行为侵犯其合法权益,有权依照本法向人民法院提起诉讼”。赋予行政相对人起诉权,只要相对人认为具体
With the implementation of the policy of opening to the outside world in our country, there has been a great development in the taxation work concerning foreign affairs and disputes and litigations in foreign-related taxation have also been gradually increasing. Therefore, the issue of foreign tax litigation has also become a research topic. In this regard, I would like to talk about the promulgation and implementation of the “Administrative Procedure Law of the People’s Republic of China”. First, foreign tax litigation and its characteristics “The People’s Republic of China Administrative Procedure Law,” the second article: “Citizens, legal persons or other organizations that the administrative agencies and administrative staff of the specific administrative acts of infringement of their legitimate rights and interests, the right in accordance with this Act Filed a lawsuit with the people’s court. ” Empower administrative counterparts to sue as long as the relatives think that they are specific