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Framework Act on National Taxes — Article 81-11 (Principle of Integrated Investigation)

국세기본법 제81조의11

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) In principle, a tax investigation shall be conducted, integrating the items of tax subject to the duty to return and pay in accordance with tax-related statutes with respect to the business of a taxpayer. <Amended on Dec. 19, 2017>

(2) Notwithstanding paragraph (1), in any of the following cases, only specific tax items may be investigated: <Newly Inserted on Dec. 19, 2017>

1. Where it is necessary to investigate specific tax items in consideration of the characteristics of tax items, taxpayer's type of return, business scale or suspicion of tax evasion, etc.;

2. Where it is necessary to investigate specific tax items urgently for the security of tax claims, etc.;

3. Other cases prescribed by Presidential Decree, where it is necessary to investigate only specific tax items in consideration of the efficiency of tax investigation, taxpayers' convenience, etc.

(3) Notwithstanding paragraphs (1) and (2), a limited investigation may be conducted for parts necessary to verify the matters in the relevant case (hereinafter referred to as "partial investigation"), in any of the following cases: <Newly Inserted on Dec. 19, 2017; Dec. 31, 2018; Dec. 31, 2022>

1. Where it is necessary to verify whether requests for correction, etc. under Article 45-2 (3); 156-2 (5) or 156-6 (5) of the Income Tax Act; or 98-4 (5) or 98-6 (5) of the Corporate Tax Act are processed; or national tax refunds under Article 51 (1) are determined;

2. Where it is necessary to verify the facts, etc. in accordance with a decision to conduct a re-investigation under the proviso of Article 65 (1) 3 (including cases applicable mutatis mutandis in Articles 66 (6) and 80-2) or under the proviso of Article 81-15 (5) 2;

3. Where it is necessary to verify part of a transaction in the middle of tax investigation for the other party to the transaction;

4. Where the tax evasion of a taxpayer is informed in detail and it is necessary to verify the suspicion of the relevant tax evasion;

5. Where it is necessary to verify the suspicion of tax evasion by means of the use of fake names and the use of borrowed accounts;

6. Other cases prescribed by Presidential Decree, where it is necessary to verify specific places of business, specific items or specific transactions in consideration of the efficiency of tax investigation, taxpayers' convenience, etc.

(4) No partial investigation on grounds falling under paragraph (3) 3 through 6, shall be conducted more than twice for the same tax item and for the same taxable period. <Newly Inserted on Dec. 19, 2017>[This Article Newly Inserted on Jan. 1, 2010]

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