When tax collection authorities are unable to determine the tax basis after investigation, or the investigation cost is disproportionally expensive, tax estimation is allowed for the principle of upholding tax equity, and the estimation basis and calculation information shall be in writing.
Tax estimation made by tax collection authorities shall be deliberated and estimated for all relevant material items, and through reasonable and objective procedures and appropriate means.
Estimation shall be by the means which is nearest to the actual amount when more than two means exist.
In the cases that taxpayers have already carried out their obligation of assistance, tax collection authorities shall not demand penalty according to the estimation results.