Is tax administrative reconsideration the pre-litigation procedure?

Q: Is tax administrative reconsideration the pre-litigation procedure?

A: "Tax Collection and Administration Law" Section 88, paragraph 1, the taxpayers,扣缴义务人, tax guarantor with the tax authorities in the event of a dispute on the tax, in accordance with the tax authorities must first determine the taxable and tax payers or Jiejiao Late fees or provide the appropriate security, then the law can apply for administrative reconsideration, administrative reconsideration of the decision against, the people's court in accordance with the law can be prosecuted. Therefore, in principle, the tax dispute, the tax is the administrative reconsideration of the pre-litigation procedure.

Of course, "Tax Collection and Administration Law" also provides for exceptions, that the parties to the tax authorities of the punishment decision, or enforcement measures against tax protective measures, in accordance with the law can apply for administrative reconsideration, but also directly to the people's courts to prosecute according to law.