新修订的《税收征管法》确立了 “税收优先”的原则，规定：“税务机关征收税款，税收优先于无担保债权，法律另有规定的除外；纳税人欠缴的税款发生在纳税人以其财产设定抵押、质押或者纳税人的财产被留置之前的，税收应当先于抵押权、质权、留置权执行”（第４５条）。这一原 The newly revised Tax Administration Law establishes the principle of “tax priority”, which stipulates that: “Tax authorities collect taxes with a tax preference over unsecured claims, except as otherwise stipulated by law; taxes owed by taxpayers are subject to tax Where a person sets up a mortgage, pledge, or property of a taxpayer with his property before it is left in his possession, the tax shall be executed prior to the mortgage, pledge, liens ”(Article 45). This original