Income Tax Act Article 110-2
Where a profit-seeking enterprise has filed an income tax return in accordance with Article 102-2 hereof, but did not report or underreported its retained surplus earnings in such tax return, it shall be subject to a fine of no more than the amount of the tax evaded.Where a profit-seeking enterprise failed to file an income tax return in accordance with Article 102-2 hereof, and was discovered by the tax authority to have failed to declare retained surplus earnings which should have been reported under this Act, it shall, in addition to paying the amount of additional income tax assessed and determined by tax authority, be subject to a fine of no more than the amount of tax determined as payable.