Regulations Governing Certified Public Accountants Acting as Income Tax Agents Article 15

n the case that during the examination of an income tax filing case that was audited and certified by a mandated CPA, the opinion of the tax collection authority on the application of accounting principles is different from the opinion of the CPA, both the tax collection authority and the CPA may refer the dispute to the R.O.C. National Association of Certified Public Accountants for review and decision.The review and decision-making procedures set forth in the preceding paragraph shall not affect the tax assessment conducted by the tax collection authority in cases with tax payable. If a taxpayer disagrees with the assessment made by the tax collection authority, the taxpayer may proceed in accordance with the administrative remedy procedures.
中文原文 會計師代理所得稅事務辦法第15條
稽徵機關於審核會計師依本辦法代理所得稅簽證申報案件,對會計原則之適用,如與受託會計師意見不一致時,稽徵機關與會計師均得送請會計師公會全國聯合會審議決定之。
前項審議程序不影響稽徵機關對有關納稅案件之核課,納稅義務人如對稽徵機關之核定不服時,仍應依行政救濟程序辦理。

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