| The right of tax subrogation system has been regulated in the new Law of the People's Republic of China on the Administration of Tax Collection, which based in Contract Law of the People's Republic of China. As for the right of tax subrogation is a new thing, the tax authorities may meet many specific legal problems when they exercise the right. Whereas the existing rules are very simple and fundamental, this paper is mainly about the legal basis of tax subrogation, its definition, legal attribute, establishment essentials, enforcement manners, scope, limits and effectiveness. The author also tries to give some advices to solve the conflicts and applicable problems in the subrogation suits. |