The tax administration law belongs to the law, and Guo Shui Fa (2004) 1 12 is a normative document. From the perspective of legal effect, the law is much higher than the normative documents. In view of the same matter, if the subordinate law violates the provisions of the superior law, the subordinate law shall be invalid and the provisions of the superior law shall apply.

However, as far as the specific content is concerned, Article 45 of the Tax Administration Law stipulates tax priority and tax arrears announcement. The Notice of State Taxation Administration of The People's Republic of China on Deducting Tax Arrears by Input Tax of General VAT Taxpayers (Guo Shui Fa (2004) 1 12No.) stipulates the problem of deducting tax arrears by general taxpayers, and there is no conflict between them.