When a tax official completes a tax investigation, he or she shall explain to the taxpayer, the results of investigation including the following matters within 20 days (40 days in cases falling under any of subparagraphs of Article 11 (1)) from the date when the investigation is completed, and notify the taxpayer thereof in writing: Provided, That the same shall not apply in cases prescribed by Presidential Decree such as where a tax manager is not determined or where a taxpayer does not have a domicile or place of residence in the Republic of Korea: <Amended on Dec. 31, 2011; Dec. 19, 2017; Dec. 31, 2018; Dec. 31, 2019>
1. Details of a tax investigation;
2. Tax bases and tax amounts to be determined or corrected, and grounds for the calculation thereof;
3. Other matters prescribed by Presidential Decree.
(2) Notwithstanding paragraph (1), where a tax official is unable to notify the findings of investigation within the period prescribed in paragraph (1) for any of the following reasons, he or she may explain the findings of investigation to the taxpayer, excluding the details of the investigation that shall not be revealed, and notify the taxpayer of such result in writing only where the taxpayer consents thereto: <Newly Inserted on Dec. 31, 2019>
1. Where consultation with a foreign tax agency is underway, due to collection or submission of foreign data or commencement of mutual agreement procedures under the Adjustment of International Taxes Act and a tax treaty;
2. Where, in relation to the relevant tax investigation, an inquiry process is being conducted by the Minister of Economy and Finance or the Commissioner of the National Tax Service for the interpretation of tax-related statutes or the confirmation of facts.
(3) When the causes provided in the subparagraphs of paragraph (2), such as the termination of the mutual agreement procedure, interpretation of tax-related statutes, or reply to an inquiry for confirmation of facts, are resolved, the head of a tax office shall explain to the taxpayer the findings of the investigation other than the part notified pursuant to paragraph (2) within 20 days (in the case falling under any subparagraph of Article 11 (1), 40 days), and shall notify him or her of said results. <Newly Inserted on Dec. 31, 2019>[This Article Wholly Amended on Jan. 1, 2010][Moved from Article 81-9 <Jan. 1, 2010>]