Income Tax Act Article 110-1

In case a taxpayer, after an additional tax payment notice has been served to him/her/it for tax evasion or omission, is suspected by the tax authority of concealing or transfering his/her/its property to evade the collection of tax, the tax authority may, with a statement of detailed facts, without furnishing any security, apply to the court for a provisional seizure of his/her/its property. But if the taxpayer has furnished property equivalent to the tax payable as security or a surety from a reliable businessman, the tax authority may file an application to the court for a withdrawal of the case or a lifting of the attachment.