People may imagine tax officials arriving suddenly one day, but on-site audits generally involveAdvance noticeadvance notice, under Article 74-9 of the General Act of National Taxes.
The statute lists what must be notified and to what extent, so you can check immediately whether the communication received satisfies the notice requirements.
Seven notification items
Article 74-9(1) provides that when a district director of a tax office or other authority has officials conduct questioning, inspection, or similar measures in an on-site audit, the taxpayer must be notified in advance of that fact and the following matters.
| # | Notification items |
|---|---|
| (i) | Date and time the audit will begin |
| (ii) | Place where the audit will be conducted |
| (iii) | Purpose of the audit |
| (iv) | Taxes covered by the audit |
| (v) | Periods covered by the audit |
| (vi) | Books, documents, and other objects covered by the audit |
| (vii) | Other matters prescribed by Cabinet Order as necessary for the proper and smooth conduct of the audit |
Item (vii) is delegated to Cabinet Order.
The point to understand here is thatitems (iii) through (vi) define the scope of the audit.The audit begins with its purpose, taxes, periods, and objects specified.
The date, time, and place can be discussed
Article 74-9(2) provides:
Where a taxpayer notified under the preceding paragraph requests, with reasonable grounds, a change to a matter listed in item (i) or (ii) of that paragraph, the district director of the tax office or other authority shall endeavor to discuss that matter.
Changes can be requested only foritem (i), the date and time, and item (ii), the place.This provision does not provide for requests to change the purpose, taxes, or periods.
It says “endeavor to discuss,” not that the request must be granted. Nevertheless, schedules are often adjusted in practice when reasonable grounds are given. If the audit overlaps with year-end closing or a busy period, it is worth making a request rather than silently accepting the date.
The tax accountant also receives notice
The parenthesis in paragraph (1) includes “the tax agent, where the taxpayer has one.” If a tax accountant has filed an authorization for tax representation, that accountant also receives notice.
Paragraphs (5) and (6) provide further rules.
- Paragraph (5): In cases prescribed by Ministry of Finance Order as involving the taxpayer's consent, notice to the taxpayermay be given solely to the tax agent.
- Paragraph (6): In cases prescribed by Ministry of Finance Order where one of several tax agents has been designated as the representative agent,notice may be given solely to the representative tax agent.
The requirements for both are delegated to Ministry of Finance Order. In practice, this concerns whether the relevant box on the authorization for tax representation has been checked.
When the discussion extends beyond the notified scope
Paragraph (4) is important.
If, during the audit, a discrepancy or violation comes to be suspected concerning mattersoutside the notified items (iii) through (vi)—purpose, taxes, periods, and objects—questioning, inspection, or similar measures concerning those matters are not precluded. The advance notice rule in paragraph (1) does not apply to those matters.
Thus, if an official conducting a corporation tax audit discovers a suspected withholding income tax violation, the official may examine that issue without giving fresh advance notice.
This is the statutory basis for situations in which “it was not in the notice, so I will not show it” does not succeed.
Who is the “taxpayer”?
Paragraph (3)(i) defines the scope of “taxpayer” for this Article by reference to the items in Articles 74-2 through 74-6. Right to inspection and questioning Among the persons subject to that authority,those listed in subitem (a)principally the taxpayer personally.
When officials visit a business counterparty for a cross-check audit, that counterparty is not the taxpayer referred to here.There is therefore no provision requiring advance notice to the counterparty.This structure explains the many consultations about the difficulty caused by unexpected visits to business partners.
Common practical questions
- Whether the notified audit period is three, five, or seven years affects how you prepare.
- We are asked whether a telephone call alone is sufficient as advance notice. The statute does not require written notice.
- How you formulate the “reasonable grounds” for requesting a schedule change can affect the tone of the subsequent audit.
If you consult us when the audit is first announced, we can begin by checking the notified scope together.
Legal basis
- Article 74-2 of the Act on General Rules for National Taxes (Authority to Question and Inspect Concerning Investigation of Income Tax, etc. by the Relevant Official)
- Article 74-6 of the General Act of National Taxes (Officials' Questioning and Inspection Authority for Investigations Concerning Aviation Fuel Tax and Other Taxes)
- Article 74-9 of the Act on General Rules for National Taxes (Prior Notice, etc., of Tax Audits to Taxpayers)
Article headings are verified using the statutory data from the e-Gov Law Search.
This article is a general commentary based on laws and regulations as of August 31, 2026. Please obtain advice on your individual circumstances before taking action.
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