n the case that during the examination of an income tax filing case that was audited and certified by a mandated CPA, the opinion of the tax collection authority on the application of accounting principles is different from the opinion of the CPA, both the tax collection authority and the CPA may refer the dispute to the R.O.C. National Association of Certified Public Accountants for review and decision.

The review and decision-making procedures set forth in the preceding paragraph shall not affect the tax assessment conducted by the tax collection authority in cases with tax payable. If a taxpayer disagrees with the assessment made by the tax collection authority, the taxpayer may proceed in accordance with the administrative remedy procedures.