(1) In any of the following cases, the commissioner of the competent regional tax office having jurisdiction over the place of tax payment of a consolidated parent corporation may revoke approval for applying the consolidated tax return system, as prescribed by Presidential Decree: <Amended on Jan. 1, 2013; Dec. 15, 2015; Dec. 31, 2022>
1. Where the business year of a consolidated corporation does not coincide with the consolidated business year;
2. Where the consolidated parent corporation applies the consolidated tax return system to a domestic corporation which it does not consolidate and control;
3. Where the consolidated tax return system is not applied to a wholly controlled subsidiary of the consolidated parent corporation;
4. Where it is impracticable to calculate the amount of income of a consolidated corporation based on accounting records or other evidentiary documents on the grounds referred to in the proviso to Article 66 (3);
5. Where there are grounds to occasionally impose corporate tax on a consolidated corporation as prescribed in Article 69 (1);
6. Where the consolidated parent corporation is consolidated and controlled by another domestic corporation (excluding nonprofit domestic corporations).
(2) Where approval for applying the consolidated tax return system is revoked under paragraph (1) during the period between the consolidated business year for which the application of the consolidated tax return system was approved and the consolidated business year that ends within four years from the start date of the following consolidated business year, each consolidated corporation for which the application of the consolidated tax return system was approved shall include the amount of income or losses in the gross income or deductible expenses for the business year in which the approval for applying the consolidated tax return system is revoked as follows; provided, the foregoing shall not apply in extenuating circumstances specified by Presidential Decree: <Added on Dec. 15, 2015>
1. The amount of income of the relevant corporation, which has been aggregated with losses of other consolidated corporations during the consolidated business years pursuant to Article 76-14 (1): To be included in gross income;
2. The amount of losses of the relevant corporation, which has been aggregated with income of other consolidated corporations during the consolidated business years under pursuant to Article 76-14 (1): To be included in deductible expenses.
(3) The consolidated tax return system shall not apply to any consolidated corporation for which approval for applying the consolidated tax return system is revoked under paragraph (1) in the business year in which the date of revocation falls and to the business year that ends within four years from the start date of the following business year, deeming the same corporation as at the time of application of the consolidated tax return system to be the consolidated parent corporation. <Amended on Dec. 15, 2015>
(4) Where approval for applying the consolidated tax return system is revoked under paragraph (1), an amount prescribed by Presidential Decree that reverts to each consolidated corporation among the amounts referred to in Article 76-13 (1) 1 shall be deemed losses in Article 13 (1) 1 of the relevant consolidated corporation. <Amended on Dec. 15, 2015; Dec. 24, 2018>
(5) Where approval for applying the consolidated tax return system is revoked under paragraph (1), the interim tax for each consolidated corporation referred to in Article 76-18 (4) among the consolidated interim tax paid under the same Article shall be deemed the interim tax referred to in Article 64 (1) 2 for purposes of Article 61 (1). <Amended on Dec. 15, 2015>
(6) Where approval for a consolidated corporation to which consolidated tax return system applies under Article 76-8 (3) to apply the consolidated tax return system is revoked under paragraph (1), the period from the start date of the consolidated business year in which the date of revocation falls to the end date of the consolidated business year, and the period from the day following the end date of the consolidated business year in which the date of revocation falls, to date preceding the start date of the original business year shall be deemed one business year, respectively. <Amended on Dec. 15, 2015>[This Article Wholly Amended on Dec. 30, 2010]