Regulations Governing Certified Public Accountants Acting as Income Tax Agents Article 14

With respect to an income tax case that was audited and certified by a mandated CPA in accordance with the provisions of these Regulations, the tax collection authority shall examine and verify the case based on the documentation filed, unless the tax collection authority has any questions or deems that further examination is required with respect to the audit report, working papers or the explanations contained in other relevant statements. Under such circumstances, the tax collection authority may send an enquiry to the CPA, or may send a notification to the CPA to submit supplementary explanations under a deadline, or may send a notification to the CPA to inform the mandator to provide relevant accounting books and record to prepare to answer any questions. However, in the event that the CPA fails to submit such accounting books and records within the prescribed time period, or is disqualified as a tax agent, or can not be notified for any other reasons, then the tax collection authority may make a direct request to the mandator for his/her/its presentation of accounting books and records for further investigation.The tax collection authority may, as permitted by its manpower, conduct periodic physical examination of the cases subject to documentary examination under the preceding paragraph provided. However, in the case of a CPA who has been evaluated and rated excellent, filings audited and certified by him/her may be exempted from such physical examination.
中文原文 會計師代理所得稅事務辦法第14條
稽徵機關對於會計師依本辦法代理所得稅簽證申報案件,除對所提供之查核報告、查核工作底稿以及其他有關表報說明尚有疑問或認為尚有應行查核事項,得向該會計師查詢,或通知會計師限期補具查核說明文件,或通知會計師向委託人調閱帳簿文據並備詢說明外,應就書面查核認定。
但會計師逾期未提送帳簿文據或喪失稅務代理人資格,或其他原因致無法通知時,稽徵機關得直接向該委託人調取帳簿文據查核。
稽徵機關得視人力許可,對前項書面查核認定案件,定期實地抽查,惟經實施評鑑績優者,其受託代理查核簽證申報之案件,得免予抽查。

English translation for reference only; the Chinese text prevails. Not legal advice.