税收情报交换涵义初探

Implications of Exchange of Tax Information

本文将税收情报交换的涵义界定为形式的两类性、主体的两重性或三重性、性质的交叉性、目的的双重性和范围的延展性五个方面。其中,性质的交叉性又体现为立法权与行政权的交叉、公法与私法的交叉、国际税法与国内税法的交叉以及实体税法与程序税法的交叉四个方面。

In this paper, tax information exchange is defined to include five aspects： duality of the form, twofold or threefold of subjects, crossing of the natures, duality of the purpose and extensibility of the scope. Crossing of the natures can be interpreted also in four parts： the crossing of the legislative power and administrative power, the crossing of public law and private law, the crossing of international tax law and domestic tax law, the crossing of substantial tax law and procedural tax law.