《税收征管法》第64条第1款规定“纳税人、扣缴义务人编造虚假计税依据的,由税务机关责令限期改正,并处五万元以下的罚款”;第63条第1款规定”……进行虚假的纳税中报,不缴或者少缴应纳税款的,是偷税。对纳税人偷税的,由税务机关追缴其不缴或少缴的税款、滞纳金,并处不缴或少缴的税款50％以上5倍以下的罚款……”。从上述两条款的内容和立法宗旨上可看出,适用第63条与第64条的主要区别在于是否造成了导致少缴税款后果。如 Paragraph 1 of Article 64 of the Law on the Administration of Tax Collection stipulates that “Where taxpayers or withholding agents make false basis for taxation, the tax authorities shall order them to make corrections within a prescribed time limit and impose a fine of not more than 50,000 yuan”; Article 63, paragraph 1 Stipulates that “...... False tax reporting, not paying or paying less tax payable is tax evasion. Tax evasion by taxpayers, the tax authorities to recover their unpaid or less paid taxes, late fees, and not paid Or less than 5% of the tax paid less than 5 times the fine ... ”. As can be seen from the contents and legislative purposes of the above two paragraphs, the main difference between the application of Articles 63 and 64 is whether the result of the tax concessions resulted. Such as