Tax Collection Act Article 49
Unless otherwise provided for under this Act, the provisions of this Act in connection with taxation shall be applicable, mutatis mutandis, to the imposition of belated surcharge, interest, delinquent reporting surcharge, non-reporting surcharge and fines; provided, however, that the tax payment priority set forth in Article 6 hereof and the provisions of Paragraph 2 of Article 26-1, Paragraph 2 and 3 of Article 38 hereof regarding interest surcharge shall not apply to the imposition of fines, delinquent reporting surcharge, and non-reporting surcharge.Where a surcharge for delayed filing of tax return and non-filing of tax return has been forwarded to the Administrative Enforcement Agency for compulsory execution before the revision on November 30 2021, the tax payment priority set forth in Article 6 hereof such provisions prior to the amendment shall apply.