This work aims to demonstrate that even within the originally subordinate legal relationship regarding tax liability between the tax office and the taxpayer, both sides have access to civil law-based rights of disposition to achieve an economically sensible exchange of services. Due to the dual functionality of set-off, it occupies a special position within the system of performance actions and may lead to modifications of the tax law's subordinate relationship due to its inherent, mutually conditioned debtor-creditor identity. This, in turn, allows for a comparative examination of the possible courses of action for the tax office that is exercising set-off, particularly concerning the sovereign enforcement of claims through administrative acts.