(1) An objection shall be filed with the head of a tax office who has issued or should have issued the relevant disposition, or with the commissioner of the competent regional tax office through the head of a tax office, with the ground for protest prepared, as prescribed by Presidential Decree: Provided, That if any of the following events occurs, an objection shall be filed with the commissioner of the competent regional tax office; and an objection filed with the head of a tax office shall be deemed filed with the commissioner of the competent regional tax office: <Amended on Jan. 1, 2010; Jan. 1, 2013; Dec. 31, 2019>
1. Where the disposition of taxation has been issued according to the investigation by the commissioner of the competent regional tax office;
2. Where a pre-assessment review has been requested to the head of a tax office under Article 81-15.
(2) If the disposition subject to objection has been or should have been investigated, decided or settled by the commissioner of a regional tax office, the head of a tax office shall forward the objection to the relevant commissioner of the regional tax office, along with the relevant application stating opinions, within seven days from the date of receipt of the objection filed and notify the person who has filed the objection of such fact. <Amended on Jan. 1, 2010>
(3) The head of a tax office in receipt of an objection addressed to the commissioner of a regional tax office under paragraph (1) shall forward the objection to the commissioner of the regional tax office, along with the relevant application stating opinions, within seven days from the date of receipt of the objection filed. <Amended on Jan. 1, 2010>
(4) The head of a tax office and the commissioner of a regional tax office, in receipt of the objection filed under paragraphs (1) and (2), shall respectively make a decision thereon, following the deliberation of the National Tax Examination Committee. <Amended on Jan. 1, 2010>
(5) Deleted. <Dec. 26, 2008>
(6) Articles 61 (1), (3), and (4), 62 (2), 63, and 63-2; the proviso of Article 64 (1) and paragraph (3) of the same Article; and Articles 65 (1), and (3) through (7), 65-2, and 65-3 shall apply mutatis mutandis to filing an objection. <Amended on Jan. 1, 2010; Dec. 20, 2016; Dec. 19, 2017; Dec. 31, 2018; Dec. 22, 2020; Dec. 31, 2022>
(7) A decision under Article 65 (1), which applies mutatis mutandis in paragraph (6), shall be rendered within 30 days from the date when an objection is filed: Provided, That where a person who has filed an objection files a plea to a written opinion served under paragraph (8) within the period for decision prescribed in the main clause of this paragraph, such decision shall be rendered within 60 days from the date when the objection is filed. <Newly Inserted on Dec. 20, 2016>
(8) The head of a tax office in receipt of an objection filed under paragraph (1) or the commissioner of a regional tax office in receipt of an objection filed or written opinion forwarded under paragraphs (1) through (3), shall immediately forward a written opinion on the disposition subject to the objection, to a person who has filed the objection. In such cases, grounds and reasons for the disposition, the fact that constitutes reasons for the disposition, etc., shall be specifically stated in the written opinion. <Newly Inserted on Dec. 15, 2015; Dec. 20, 2016>[Title Amended on Dec. 31, 2007]