Income Tax Act Article 83-1

If the tax authority or a tax investigator designated by the MOF discovers a taxpayer is suspected of tax evasion or omission in substantial amounts, the authority or investigator may, as the case merits, report to the MOF for approval to institute a further investigation on the taxpayer's net assets, fund flowing, and other business data which are not conformable to the regular business practice.If the result of a further investigation, as prescribed in the preceding paragraph, conducted by the tax authority or tax investigator proves that the taxpayer has evaded and/or omitted taxes, the taxpayer shall be responsible for bearing the burden of proof.