In fact, there is a relation of obligation and debt between the government and taxpayers in public law, and the executive punishment of taxation is a punishment done by the government to the taxpayers who broke the tax contract. 事实上,国家和纳税人之间是一种公法意义上的债权债务关系,税务行政处罚是国家对纳税人不按时履行税收合约的一种惩罚。
The Adjoining Relation System in German Public Law 德国公法相邻关系制度初论