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平等原则不仅仅体现在权利平等方面,还表现在履行义务上的平等。义务平等的意义在某些程度上不亚于权利的平等保护,它有自己独立的存在价值。公民缴纳税款时,相同情况要得到相同对待,差别情况应得到差别对待,在个税缴纳中,更重要的还在于实质平等。在个人所得税问题上,效率和公平的位置应当予以调换,即“公平优先,兼顾效率”,这是宪法基本原则之一———纳税义务平等原则的要求。
The principle of equality is not only reflected in the equality of rights, but also in the fulfillment of obligations of equality. To some extent, the meaning of equal obligation is no less than the equal protection of rights. It has its own independent existence value. Citizens pay taxes, the same situation should be treated the same, the differences should be treated differently, in the tax payment, more important still lies in substantive equality. On the issue of personal income tax, the position of efficiency and fairness should be replaced by “giving priority to fairness and taking efficiency into account”. This is one of the basic principles of the Constitution --- the principle of equality of tax payment obligations.