征税依据是一个十分重要的税收基础理论问题，中外学者就此问题都进行了长期的探讨，并形成了诸多学说。“权益说”（包括“权力说”、“利益说”、“义务说”，下同）与“交换说”是当代具有代表性的两种观点。“权益说”认为，国家为实现其职能，维护政治统治、公共安全和公 The basis for taxation is a very important issue of taxation theory. Both Chinese and foreign scholars have conducted long-term discussions on this issue and formed many theories. “Equity theory” (including “power theory”, “interest theory”, “obligation theory”, the same below) and “exchange theory” are two representative contemporary views. “Rights and Interests,” said that the state in order to achieve its functions, safeguarding political rule, public safety and public