《征管法》第五十条规定了税 务机关在追缴欠税中可以行使代位权。代位权是《合同法》规定的合同保全的手段之一，将这一手段应用于税收征管之中，对于抑制欠税，特别是对那些以消极态度恶意放弃债权以逃避国家税收的欠税人来说，无疑是一种有效的控管手段。但是应该注意的是， Article 50 of the Law on the Administration of Taxes stipulates that tax authorities may exercise subrogation right in the recovery of tax arrears. Subrogation is one of the means of contract preservation stipulated in the Contract Law. This measure is applied to tax collection and administration. It is also an effective way to suppress tax arrears, especially for taxpayers who maliciously give up their claims in a negative attitude to evade state taxes Is undoubtedly an effective means of control. However, it should be noted that,