税收撤销权中存在税务机关、纳税人、第三人等当事人。第三人与税务机关之间本无任何法律关系 ,仅与纳税人之间存在财产交易关系。由于税收撤销权的行使 ,第三人从中得到的财产利益不复存在 ,从而成为其中最大的利益受损方。本文认为 ,税收撤销权保全税收债权的功能固然无可厚非 ,但是第三人的利益也需要尽可能地保护。为了防止税务机关滥用权利 ,侵害第三人的合法利益 ,税收撤销权不仅应当满足实体要件 ,同时也要遵循一定的程序规范。我国立法虽然对此有所要求 ,但实践中究竟如何解释和适用 ,人们在观念上还存在较大的差异。因此 ,非常有必要从第三人利益保护的角度 ,重新审视税收撤销权的内容。 There are tax authorities, taxpayers, third parties and other parties in the tax withdrawal right. There is no legal relationship between the third party and the tax authorities, and there is a property transaction relationship only with taxpayers. Due to the tax-rescission right, the property interest obtained by the third party ceased to exist and thus became the biggest loser. This paper argues that the tax avoidance right to preserve the function of tax claims is understandable, but the interests of third parties also need to be protected as much as possible. In order to prevent tax authorities from abusing their rights and violating the legitimate interests of the third party, tax avoidance rights should not only meet the substantive requirements but also follow certain procedural norms. Although our country’s legislation requires this, how to interpret and apply it in practice, there are still a lot of differences in people’s concept. Therefore, it is very necessary to review the contents of tax avoidance right from the perspective of the protection of the third party.