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企业所得税的汇算清缴既涉及到纳税人确定其应纳税额的自我课赋行为，也涉及到税务机关依据税收征管权所进行的清算、审核和指导行为。１９９５年汇算请缴改革以后，虽然明确了纳税人自我评估申报行为的法律责任，但对税务机关在汇算清缴期间应负有的程序义务和法律责任不够明
The settlement and payment of enterprise income tax involves both the taxpayer’s self-assessment of taxable amounts and the liquidation, examination and guidance of the tax authorities on the basis of the tax collection and administration authority. Although the taxpayer’s legal responsibility for self-assessment of declarations was clarified after the payment for the reform was made in 1995, the procedural obligations and legal responsibilities that the tax authorities should have during the settlement of the accounts were not clear enough