Abstract: The narrow concept of taxpayers in Chinas current anti-tax avoidance legislation may lead to tax avoidance via the related parties and CFCs. Therefore， it is necessary to clarify the concept of “accessory taxpayer” in the total-fraction mode， which is transferred and established from the foreign concept of second taxpayers. Accessory tax obligation is a public guarantee of debts， deriving from the theory of tax credits and debts. Based on the equity theory of international governance， it is proposed that China should formulate the relevant types of accessory tax obligation and ascertain the varied accessory tax obligations based on the occurrence of tax-avoidance acts. Only when tax-avoidance acts occur should the parties concerned undertake the supplementary accessory obligations while the CFCs are bound to undertake the collateral obligations.

Key words: taxpayer, accessory taxpayer, anti-tax avoidance, tax debt