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Framework Act on National Taxes — Article 55 (Protest)

국세기본법 제55조

This English translation is based on the Korean text effective 2024-01-01. The Korean law has since been amended (current version effective 2026-10-02) — check the Korean original.

(1) Any person whose rights or interests have been infringed on, by receiving an unlawful or unreasonable disposition or due to failure to receive a required disposition under this Act or other tax-related statutes, may request the revocation or modification of such disposition or request other necessary dispositions pursuant to this Chapter: Provided, That the same shall not apply to any of the following dispositions: <Amended on Jan. 1, 2010; Dec. 20, 2016; Dec. 31, 2019>

1. Disposition of notification under the Procedure for the Punishment of Tax Offenses Act;

2. Disposition by which a request for examination is filed under by the Board of Audit and Inspection Act or dispositions on such request for examination;

3. Disposition to impose an administrative fine under this Act and other tax-related statutes.

(2) An interested person falling under any of the following subparagraphs, whose rights and interests are to be infringed on due to a disposition pursuant to this Act or other tax-related statutes, may request the revocation or modification of an unlawful or unreasonable disposition imposed on a person or request other necessary dispositions pursuant to this Chapter: <Amended on Jan. 10, 2010; Dec. 19, 2017; Dec. 22, 2020; Dec. 29, 2020>

1. A person secondarily liable to pay taxes who has received a notice of payment;

2. A person who has received a notice of payment as he or she has to bear the liability of tax payment in kind pursuant to Article 42;2-2. A person liable to pay taxes in kind pursuant to Article 3-2 of the Value-Added Tax Act, who receives a notice of payment under Article 52-2 (1) of the same Act;2-3. A person liable to pay taxes in kind pursuant to Articles 7-2 and 12-2 of the Comprehensive Real Estate Holding Tax Act, who receives a notice of payment under Article 16-2 (1) of the same Act;

3. A guarantor;

4. Other persons prescribed by Presidential Decree.

(3) Except for the cases of dispositions prescribed in paragraphs (1) and (2) which are to be or should have been examined, determined or managed by the Commissioner of the National Tax Service, an objection may be filed pursuant to this Chapter before a request for examination or adjudgment against such dispositions is made. <Amended on Jan. 1, 2010>

(4) Deleted. <Aug. 31, 1999>

(5) No objection or no request for examination or adjudgment shall be filed against dispositions on request for examination or request for adjudgment under this Chapter: Provided, That with regard to dispositions issued by a disposition agency following a decision to conduct a re-investigation prescribed in the proviso of Article 65 (1) 3 (including cases applicable mutatis mutandis in Article 80-2), a request for examination or adjudgment may be filed against the ruling agency that has made the relevant decision to conduct a re-investigation. <Amended on Dec. 20, 2016; Dec. 31, 2022>

(6) No objection shall be filed against dispositions on objections under this Chapter and against dispositions issued by a disposition agency following a decision to conduct a re-investigation prescribed in the proviso of Article 65 (1) 3 (referring to cases applicable mutatis mutandis in Article 66 (6)). <Newly Inserted on Dec. 20, 2016>

(7) Deleted. <Jan. 1, 2010>

(8) Deleted. <Jan. 1, 2010>

(9) No overlapping requests for examination and adjudgment on the same disposition shall be filed. <Amended on Jan. 1, 2010>[Title Amended on Jan. 1, 2010]

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Korean original (law.go.kr) · Get articles as JSON via API