Legal basis: Rules for Tax Administrative Reconsideration Article 2 These Rules shall apply to citizens, legal persons and other organizations (hereinafter referred to as applicants) who think that a specific administrative act of the tax authorities has infringed upon their legitimate rights and interests and apply to the tax administrative reconsideration authorities for administrative reconsideration.
People's Republic of China (PRC) Administrative Reconsideration Law
Article 2 This Law is applicable to citizens, legal persons or other organizations who believe that a specific administrative act has infringed upon their legitimate rights and interests and apply for administrative reconsideration to the administrative organ that accepted the application for administrative reconsideration and made the decision on administrative reconsideration.
Article 5 If a citizen, legal person or other organization refuses to accept the decision of administrative reconsideration, it may bring an administrative lawsuit to the people's court in accordance with the provisions of the Administrative Procedure Law, unless the decision of administrative reconsideration is final according to law.