A taxpayer may, when disagreeing with the decision on the recheck application rendered by the tax collection authorities, file an administrative appeal and initiate an administrative litigation.

In the event that the final recheck decision, or the final decision of appeal, or the judgment rendered with respect to an administrative appeal or an administrative litigation rules that a refund of tax shall be made to the taxpayer, the tax collection authorities shall return the tax refund within ten (10) days after the date on which the recheck decision concerned is made, or after receipt of the written decision on an administrative appeal or the original copy of the judgment rendered by an administrative court, and shall concurrently pay to the taxpayer the daily interest accrued on the amount of the refundable tax at the interest rate based on the fixed interest rate on January 1 of each year for one-year time deposit of postal savings, for the period from the date on which the taxpayer originally made the tax payment to the date the tax refund notice was issued by the tax collection authorities , or the date the check was issued by the national treasury.

In the event that the final recheck decision, or the final decision of appeal, or judgment rendered with respect to an administrative appeal or an administrative litigation rules that a supplementary payment of tax shall be made by the taxpayer, the tax collection authorities shall issue a notice to the taxpayer concerned demanding the supplementary payment of tax to be made within ten (10) days after the date on which the recheck decision concerned is made, or after receipt of the final written decision on an administrative appeal or the original copy of the judgment rendered by an administrative court, and shall charge the taxpayer the daily interest accrued on the amount of such supplementary tax at the interest rate based on the fixed interest rate on January 1 of each year for one-year time deposit of postal savings, for the period from the date following the original deadline for making the payment of such tax to the date said notice was issued demanding supplementary payment of tax.

In cases where the litigation procedures were concluded in recheck, administrative appeal or administrative litigation prior to the amendment and enforcement of this Article on January 10, 2011, but the tax collection authorities have not yet delivered the refund notice, refund check or supplementary tax payment notice, or have delivered pending the decision of interest rate for administrative remedy, the provisions after the amendment shall apply. However, if the provisions prior to the amendment are more favorable to the taxpayer(s), such provisions prior to the amendment shall apply.