《征管法》中的偷税概念应改为逃税,偷税概念并不切合词义,与现代税收理念不相协调,也不符合国际惯例。偷税的立法表述不应采用列举手段的方式,而应界定其欺骗和隐瞒的实质。偷税是违反税收法律、行政法规的行为,一般的违规行为不应作为偷税。修订偷税立法应与健全税收法律责任体系相结合。 The concept of tax evasion in the Tax Administration Law should be changed to tax evasion. The concept of tax evasion does not fit the meaning of the word and is incompatible with the concept of modern taxation nor does it conform to international practice. Legislation on tax evasion should not adopt the means of enumeration but should define the substance of its deception and concealment. Tax evasion is a violation of tax laws and administrative regulations. Ordinary infractions should not be used as tax evasion. Amendment of tax evasion legislation should be combined with sound tax legal responsibility system.