Tax Collection Act Article 35

A taxpayer may, when disagreeing with the decision made in a tax assessment notice, file an application in the statutory format for recheck, stating therein the reasons for disagreement along with evidentiary documents, and in accordance with the following provisions:1.In the event where an amount of tax payable or tax shortage is stated in the tax assessment notice, an application for recheck shall, after receipt of the Tax Payment Slip, be filed within thirty (30) days from the date following the expiration date of the period for payment of said tax;2.In the event where no tax payable or tax shortage is stated in the tax assessment notice, an application for recheck shall be filed within thirty (30) days from the date following the date of receipt of the tax assessment notice; or3.In the event where the tax authorities issued the tax assessment notice to collective joint-owners or by public announcement, an application for recheck shall, after receipt of the Tax Payment Slip, be filed within thirty (30) days from the date following the expiration date of the period for payment of said tax under Paragraph 3, Article 19.4.In the event where the tax authority announced and served the notice of tax assessment in accordance with Paragraph 4 of Article 19 or other Acts, an application for recheck shall be filed within thirty (30) days from the date following the announcement date.Whether an application for recheck is filed shall be determined on the date which the tax authority receives it; however, if the application is sent to the tax authority by mail, the postmark date stamped by the original post office shall be referred.In the event where a taxpayer or his/her/its agent has failed to apply for recheck within the statutory period due to the occurrence of a natural disaster, incident, or an event of force majeure, the taxpayer or his/her/its agent may, within one month after the extinguishment of the cause of delay, file an application, along with concrete evidence, for reinstatement of original conditions provided; however, no recheck application shall be allowed if the period of delay in applying for recheck exceeds one year.After receipt of an application for recheck, the tax authorities shall make a decision on the recheck within two months from the date following the date of receiving the application from the tax payers. If all the collective joint-owners are collectively regarded as the taxpayer, the tax authorities shall make a decision combining all applications for recheck within two months from the date following the expiration date of the period during which the last joint-owner may apply for recheck.In the event that the tax authorities fail to make a decision upon the expiry of the period set forth in the preceding Paragraph, the taxpayer may file an administrative appeal without further notice.