① Different in nature. Tax administrative reconsideration is the administrative activity of administrative organs, and tax administrative litigation is the judicial activity of judicial organs.

② Different jurisdictions. In principle, tax administrative reconsideration shall be under the jurisdiction of the tax authorities at the next higher level or the people's government at the same level; Tax administrative litigation shall be under the jurisdiction of the people's court.

③ Different trial methods and procedures. The people's courts shall practise a system of collegiate bench, recusal, open trial, final trial of second instance and debate in the trial of tax administrative cases; However, the tax reconsideration organ reviews tax reconsideration cases on the principle of written review (other methods are adopted when necessary) and implements the first-level reconsideration system.

④ The effect is different. The people's court's judgment or ruling on tax administrative cases is final, and the parties who refuse to accept the judgment or ruling can only appeal, and the appeal does not affect the execution of the court's ruling; Tax administrative reconsideration is different. Except for the ruling made by the State Council, the tax administrative reconsideration decisions made by other reconsideration organs are not final. If the applicant refuses to accept the reconsideration decision, he may bring a lawsuit to the people's court.