在实践中不少人认为税务机关的查补税款全部都是纳税人的偷税款。笔者认为这种看法不符合（税收征管法）和新（刑法）对偷税作出的明确界定,混淆了查补税款和偷税款两个不同的概念。查补税款和偷税款不仅在内容和性质上不同,而且在追征期和处理上也不一样。 从内容上看,查补税款至少应由以下几个部分构成:一是愉税款,即纳税人或扣缴义务人采取伪造、变造、隐匿、擅自销毁帐簿、记帐凭证,在帐簿上多列支出或者不列、少列收入,经税务机关通知申报而拒不申报或者进行虚假的纳税申报的手段,不缴或者少缴的应纳税款或已收。已扣税款;二是骗税款,即以假报出口或者其他欺骗手段,骗取的国家出口退税款;三是避税款,即纳税人在不符合税收法理的内在要求情况下滥用税法而少缴或未缴的税款,如纳税人因采取转让定价、居所迁移、延期纳税等方式不缴或少缴的应纳税款;四是“漏税”款,即因税务机关责任或者因纳税人、扣缴义务人计算错误等失误,未缴或者少缴的税款,包括税务机关定额滞后的补差款,纳税人、扣缴义务人因未及时获悉税法新规定、对税法理解偏差（如对增值税和营业税有关税目的界定理解偏差）、依据纳税申报的会计核算有误差、纳税申报算术上的错误等原因未缴或者少缴的税款;五是正常清算税款,如企业兼并 In practice, many people think that the tax authorities’ supplementary taxes are all tax evasion by taxpayers. The author believes that this view does not meet the (tax collection law) and the new (criminal law) to make a clear definition of tax evasion, confusing the two different concepts of checking taxes and tax evasion. Recovering taxes and tax evasion is not only different in content and nature, but also different in the period of recovery and treatment. From the content point of view, the tax revenue at least should be composed of the following components: First, the tax happy, that taxpayers or withholding agents to forge, alter, hide, unauthorized destruction of books, vouchers, at Taxpayers who do not pay or pay less or have not paid taxes due to misstatement or miscarriage of income in the books and income tax, tax rebates declared by the tax authorities and refusals to declare or false tax returns. Tax deductions have been deducted; the second is tax fraud, that is, false export or other deception means to deceive the country’s export tax rebate; third is tax avoidance, taxpayers tax laws that do not meet the inherent requirements of abuse of tax law and less Tax paid or not paid, such as taxpayers due to take the transfer pricing, relocation of residence, deferred tax payable or less tax payable; Fourth, “tax evasion” paragraph, that is, due to tax authorities or taxpayers, Taxpayers and withholding agents fail to understand the new tax law in time and understand the tax law deviation (such as the value added Tax and business tax related to the definition of the understanding of the tax deviation), based on the tax accounting error, tax returns arithmetical errors and other reasons unpaid or less tax; Fifth, the normal liquidation of taxes, such as mergers and acquisitions