National Tax Collection Act

The National Tax Collection Act (Act No. 21 of 1897) is revised in its entirety.

The purpose of this Act is to secure national tax revenue through the proper realization of the people's tax liability, while achieving coordination with the private law order, by providing for the matters necessary for the execution of the delinquent tax collection procedure for national taxes and other procedures concerning collection.

In this Act, the meanings of the terms set forth in the following items are as prescribed respectively in those items:

An association or foundation that is not a corporation and for which a representative or administrator has been designated (hereinafter referred to as an "association or foundation without legal personality") is deemed to be a corporation, and the provisions of this Act apply to it.

National tax is to be collected from the total property of the taxpayer in preference to all public charges and other claims, except as otherwise provided in this Chapter.

Where a compulsory liquidation procedure is carried out with respect to a taxpayer's property, if a request for share distribution has been made for national tax, that national tax is to be collected, next after the expenses of that procedure, from the money to be distributed through that procedure (hereinafter in this Chapter referred to as "proceeds of realization").

Where a taxpayer's property has been realized through the delinquent tax collection procedure for national tax, the expenses for the delinquent tax collection procedure relating to that delinquent tax collection procedure are to be collected from the proceeds of realization in preference to other national tax, local tax and other claims, notwithstanding the provisions of the following Article, Articles 14 through 17 (Priority of National Tax for Which Security Was Taken, etc.), Article 18-2, paragraph (1) (Priority of Enterprise Value Charge Established on or before the Statutory Due Date for Tax Payment, etc.), Articles 19 through 21 (Priority of Statutory Liens, etc.), and Article 23 (Priority of Claims Secured by Provisional Registration Made on or before the Statutory Due Date for Tax Payment, etc.).

Consumption tax, etc. collected under Article 39 (Special Provisions for Collection of Consumption Tax, etc. in Case of Compulsory Liquidation) of the Act on General Rules for National Taxes or Article 8, paragraph (1), item (iii) or item (vii) (Collection of National Consumption Tax in Case of Public Sale or Sale, etc.) of the Act on Collection, etc. of National Consumption Tax Imposed on Imported Goods (Act No. 37 of 1955) (including the expenses for the delinquent tax collection procedure therefor) is, notwithstanding the provisions of Articles 12 through 17 (Priority of National Tax by Prior Seizure, etc.), Article 18-2, paragraph (1) (Priority of Enterprise Value Charges Created on or before the Statutory Due Date for Tax Payment, etc.) and Articles 19 through 21 (Priority of Statutory Liens, etc.), collected from the proceeds of realization of the goods pertaining to the removal, public sale or sale that gave rise to the collection, in priority to other national tax, local tax and other claims.

①Where seizure has been made under the delinquent tax collection procedure for national tax on the property of a taxpayer, if a request for share distribution of other national tax or local tax is made, the national tax pertaining to that seizure is collected from the proceeds of realization in priority to the other national tax or local tax pertaining to the request for share distribution.

②Where seizure has been made under the delinquent tax collection procedure for national tax or local tax on the property of a taxpayer, if a request for share distribution of national tax is made, the national tax pertaining to the request for share distribution is collected from the proceeds of realization next after the national tax or local tax pertaining to the seizure (excluding expenses to which the provisions of Article 9 (Priority of Expenses of Compulsory Liquidation Procedure) apply).

Where a compulsory liquidation procedure (excluding bankruptcy proceedings) has been carried out on the property of a taxpayer, if requests for share distribution of national tax and local tax are made, then from the proceeds of realization, the national tax pertaining to the earlier request for share distribution is collected in priority to the national tax or local tax pertaining to the later request for share distribution, and the national tax pertaining to the later request for share distribution is collected next after the national tax or local tax pertaining to the earlier request for share distribution.

Where there is property provided as security for national tax, notwithstanding the provisions of the preceding two Articles, that national tax is collected from the proceeds of realization in priority to other national tax and local tax.

①Where a taxpayer has established a pledge on the taxpayer's property, if the pledge was established on or before the statutory due date for tax payment of the national tax (for the national taxes listed in the following items, the day specified in each such item, and for accessory tax and expenses for the delinquent tax collection procedure pertaining to such national tax, the day specified in each such item for the national tax that gave rise to their collection; hereinafter referred to as the "statutory due date for tax payment, etc."), that national tax is collected from the proceeds of realization next after the claim secured by the pledge.

②The provisions of the preceding paragraph apply to a pledge other than a pledge that can be registered (including registration and the electronic record prescribed in Article 2, paragraph (1) (Definitions) of the Electronically Recorded Monetary Claims Act (Act No. 102 of 2007); the same applies hereinafter) only where the pledgee proves the fact of its establishment to the enforcement agency in a compulsory liquidation procedure. In this case, for a pledge other than a pledge whose object is securities, the proof must be made by means of the following documents:

③A pledge proved under the items of the preceding paragraph is deemed, for the purpose of applying the provisions of paragraph (1), to have been established on the day that is deemed to be a fixed date under the provisions of Article 5 (Instruments with Fixed Date) of the Act for Enforcement of the Civil Code.

④A person holding a pledge under paragraph (1) may not exercise priority against a subsequent pledgee who takes priority over the national tax under the provisions of paragraph (1), within the scope of the amount that ranks after the national tax because the person did not make the proof under paragraph (2).

Where a taxpayer has established a mortgage on the taxpayer's property on or before the statutory due date for tax payment, etc. of national tax, that national tax is collected from the proceeds of realization next after the claim secured by the mortgage.

①Where a taxpayer has acquired property on which a pledge or mortgage has been established, national tax is collected from the proceeds of realization next after the claim secured by the pledge or mortgage.

②The provisions of the preceding paragraph apply to a pledge other than a pledge that can be registered only where the pledgee proves, to the enforcement agency in a compulsory liquidation procedure, the fact that the pledge was established before the acquisition under that paragraph. In this case, the provisions of Article 15, paragraph (2), second sentence and paragraph (3) (Proof of Pledges Having Priority) apply mutatis mutandis.

①The principal amount of a claim secured by a pledge or mortgage that takes priority over national tax under the provisions of the preceding three Articles is limited to the amount of the claim at the time when the pledgee or mortgagee received notice of the seizure or request for share distribution pertaining to that national tax; provided, however, that this does not apply where it would prejudice the rights of a person holding another claim that takes priority over that national tax.

②If registration of an increase in the amount of the claim or the maximum amount secured by a pledge or mortgage is made, the provisions of the preceding three Articles apply as if, at the time of that registration, a pledge or mortgage had been newly created in respect of the increased amount of the claim or maximum amount.

①Where a taxpayer has established an enterprise value charge on the taxpayer's property on or before the statutory due date for tax payment, etc. of national tax, that national tax is collected from the proceeds of realization next after the claim secured by the enterprise value charge.

②The principal amount of a specified secured claim prescribed in Article 6, paragraph (4) (Definitions) of the Act on the Promotion of Business Financing, etc. (Act No. 52 of 2024) that is secured by an enterprise value charge that takes priority over national tax under the provisions of the preceding paragraph is limited to the amount of the claim at the time when the holder of the enterprise value charge received notice of the seizure or request for share distribution pertaining to that national tax; provided, however, that this does not apply where it would prejudice the rights of a person holding another claim that takes priority over that national tax.

①Where any of the following statutory liens exists on a taxpayer's property, national tax is collected from the proceeds of realization next after the claim secured by that statutory lien:

②The provisions of items (iii) through (v) of the preceding paragraph (excluding statutory liens listed in item (iii) of that paragraph that have been registered) apply only where the holder of the statutory lien proves to the enforcement agency, in a compulsory liquidation procedure, the fact that the statutory lien exists.

①Where any of the following statutory liens has existed on a taxpayer's property since on or before the statutory due date for tax payment, etc. of national tax, or where the taxpayer has acquired property subject to such a statutory lien, that national tax is collected from the proceeds of realization next after the claim secured by that statutory lien:

②The provisions of paragraph (2) of the preceding Article apply mutatis mutandis to the statutory lien listed in item (i) of the preceding paragraph.

①Where a right of retention exists on the property of a taxpayer, if the property is realized by the delinquent tax collection procedure, the national tax is collected from the proceeds of realization next after the claim that was secured by the right of retention. In this case, that claim is to be distributed in priority to a claim secured by a pledge, mortgage, statutory lien, or the provisional registration for security prescribed in Article 23, paragraph (1) (Priority of Claims Secured by Provisional Registrations Made on or before the Statutory Due Date for Tax Payment, etc.).

②The provisions of the preceding paragraph apply only where the holder of the right of retention proves the fact that the right of retention exists to the administrative agency, etc. in the delinquent tax collection procedure.

①Where a taxpayer does not have other sufficient property to appropriate to national tax, if the taxpayer has transferred property on which the taxpayer established a pledge or mortgage registered after the statutory due date for tax payment, etc. of that national tax, then only where it is found that the national tax would still be insufficient even if the delinquent tax collection procedure were executed against the taxpayer's property, that national tax may be collected from the pledgee or mortgagee, out of the amount they are to receive by distribution in respect of the claim secured by the pledge or mortgage in the compulsory liquidation procedure for the property relating to the transfer.

②The amount that may be collected under the preceding paragraph may not exceed the amount obtained by deducting the amount listed in item (ii) from the amount listed in item (i).

③In order to collect national tax under the provisions of paragraph (1), the district director may subrogate to the pledgee or mortgagee referred to in that paragraph and enforce the pledge or mortgage.

④When the district director intends to collect national tax under the provisions of paragraph (1), the district director must notify the pledgee or mortgagee to that effect.

⑤Where a compulsory liquidation procedure has been carried out for the property relating to the transfer referred to in paragraph (1), the district director may make a request for share distribution to the enforcement agency for the national tax in the amount that may be collected under the provisions of that paragraph.

①Where a provisional registration or provisional recording based on a contract for establishment of security interest by use of provisional registration prescribed in Article 1 (Purpose) of the Act on Contract for Establishment of Security Interests by Use of Provisional Registration (Act No. 78 of 1978) (hereinafter referred to as a "provisional registration for security") has been made, on or before the statutory due date for tax payment, etc. of national tax, on a taxpayer's property with the taxpayer as the person obliged to register (including a person obliged to record), that national tax is collected from the proceeds of realization next after the claim secured by that provisional registration for security.

②Where, on a taxpayer's property for which a provisional registration for security has been made, there is a statutory lien listed in the items of Article 19, paragraph (1) (Priority of Statutory Liens for Preservation of Real Property, etc.), or there has been, since on or before the statutory due date for tax payment, etc. of national tax, a statutory lien listed in the items of Article 20, paragraph (1) (Priority of Statutory Liens for Lease of Real Property, etc. Existing on or before the Statutory Due Date for Tax Payment, etc.), or a pledge or mortgage has been established or a provisional registration for security has been made on or before the statutory due date for tax payment, etc. of the national tax, that national tax is collected, from the proceeds of realization relating to the settlement money prescribed in Article 3, paragraph (1) (Settlement Money) of the Act on Contract for Establishment of Security Interests by Use of Provisional Registration (including where applied mutatis mutandis pursuant to Article 20 (Application Mutatis Mutandis to Contracts Whose Object Is a Right Other Than Ownership of Land, etc.) of that Act), next after the claims secured by those statutory liens, pledges and mortgages whose rights have been exercised under the provisions of Article 4, paragraph (1) (Subrogation) of that Act (including where applied mutatis mutandis pursuant to Article 20 of that Act), and by the subsequent provisional registrations for security prescribed in Article 4, paragraph (2) of that Act whose rights have been exercised under the provisions of Article 4, paragraph (1) of that Act as applied mutatis mutandis pursuant to Article 4, paragraph (2) of that Act (including where applied mutatis mutandis pursuant to Article 20 of that Act).

③The provisions of Article 17, paragraph (1) (Priority of Pledges or Mortgages Created before Acquisition) apply mutatis mutandis where a taxpayer has acquired property on which a provisional registration for security has been made, and the provisions of the preceding Article (excluding paragraph (3)) apply mutatis mutandis where a taxpayer who does not have other sufficient property to appropriate to national tax has transferred property on which the taxpayer made a provisional registration for security after the statutory due date for tax payment, etc. of that national tax, respectively.

④A provisional registration and a provisional recording based on a contract for establishment of security interest by use of provisional registration prescribed in Article 1 of the Act on Contract for Establishment of Security Interests by Use of Provisional Registration, under which the monetary obligation to be extinguished is not specified at the time of the contract, have no effect in the delinquent tax collection procedure for national tax.

①Where a taxpayer is delinquent in paying national tax, if there is property that the taxpayer has transferred and that has become the object of security by that transfer (hereinafter referred to as "property transferred as security"), the taxpayer's national tax may be collected from the property transferred as security only where it is found that the national tax to be collected would still be insufficient even if the delinquent tax collection procedure were executed against the taxpayer's property.

②When the district director intends to collect under the provisions of the preceding paragraph, the district director must give notice, by a document stating the amount to be collected and other necessary matters, to the right holder of the property transferred as security (hereinafter referred to as "holder of property transferred as security"). In this case, the district director must notify that fact to the district director competent over the location of the holder's domicile or residence (including offices and places of business; the same applies hereinafter) and to the taxpayer.

③If the amount to be collected has not been paid in full by the day on which 10 days have elapsed from the day on which the written notice under the preceding paragraph was issued, a collection official may execute the delinquent tax collection procedure against the property transferred as security, deeming the holder of property transferred as security to be a secondary taxpayer. In this case, the provisions of Article 32, paragraphs (3) through (5) (General Rules on Secondary Tax Liability) and Article 90, paragraph (3) (Restrictions on Realization) apply mutatis mutandis.

④Where property transferred as security has been seized as the taxpayer's property referred to in paragraph (1), the delinquent tax collection procedure may be continued by treating the seizure as seizure under the provisions of the preceding paragraph, only where the requirements of paragraph (1) are met. In this case, the district director must without delay give the notice and make the notification under paragraph (2).

⑤When continuing the delinquent tax collection procedure under the provisions of the preceding paragraph, if the property transferred as security is property listed in the following items, the district director must notify the person specified in each such item that the delinquent tax collection procedure will be continued by treating the seizure made as seizure of the taxpayer's property as seizure under the provisions of paragraph (3).

⑥When continuing the delinquent tax collection procedure under the provisions of paragraph (4), if there is a known person among those listed in Article 55, item (i) or item (iii) (Notice of Seizure to Pledgees, etc.), the district director must notify them that the delinquent tax collection procedure will be continued by treating the seizure made as seizure of the taxpayer's property as seizure under the provisions of paragraph (3).

⑦Where, after notice under the provisions of paragraph (2) has been given or seizure subject to the provisions of paragraph (4) has been made, the claim secured by the transfer of the taxpayer's property is extinguished by default or for any other reason except performance (including where a contract of repurchase, reservation of resale or any similar contract has been concluded with respect to the property transferred as security and that contract loses effect for a reason other than performance of the contract, such as lapse of a time limit), the provisions of paragraph (3) apply even in that case, deeming the property to continue to exist as property transferred as security.

⑧The provisions of paragraph (1) do not apply where, on or before the statutory due date for tax payment, etc. of national tax, there is registration of transfer of rights relating to a transfer made for the purpose of security, or where the holder of property transferred as security proves, by the day before the decision to sell the property, that the property had become property transferred as security on or before the statutory due date for tax payment, etc. of the national tax. In this case, the provisions of Article 15, paragraph (2), second sentence and paragraph (3) (Proof of Pledges Having Priority) apply mutatis mutandis.

⑨A holder of property transferred as security who is subject to the provisions of paragraph (1) is deemed to be a taxpayer for the purpose of applying the provisions of Chapter X (Penal Provisions).

①Where there is property transferred as security for which registration of a sale with a special agreement of repurchase, provisional registration (including provisional recording; the same applies hereinafter) for the preservation of a claim under a reservation of resale, or other similar registration (hereinafter in this Article referred to as "registration of repurchase right, etc.") has been made, and the right holder of the registration of repurchase right, etc. is a delinquent taxpayer, the seized right pertaining to the registration of repurchase right, etc. and the property transferred as security with that registration of repurchase right, etc. that has been seized under the provisions of paragraph (3) of the preceding Article may be realized together.

②Beyond what is prescribed in the preceding Article and the preceding paragraph, matters necessary for the collection of a taxpayer's national tax from property transferred as security are specified by Cabinet Order.

Where, in a compulsory liquidation procedure, national tax competes with other national tax, local tax, or public charges (hereinafter in this Article referred to as "local tax, etc.") and other claims (hereinafter in this Article referred to as "private claims"), and under the provisions of this Chapter, the Local Tax Act, or other Acts, the national tax takes priority over the local tax, etc., and the private claims are subordinate to the local tax, etc. and take priority over that national tax, or the national tax is subordinate to the local tax, etc., and the private claims take priority over the local tax, etc. and are subordinate to that national tax, the distribution of the proceeds of realization is as provided in the following items.

①When the district director intends to collect a taxpayer's national tax from a secondary taxpayer, the district director must give notice to that person, as provided by Cabinet Order, by a written payment notice stating the amount to be collected, the payment deadline, and other necessary particulars. In this case, the district director must notify the district director who has jurisdiction over the location of that person's domicile or residence to that effect.

②If the secondary taxpayer does not pay the national tax in full by the payment deadline under the preceding paragraph, the district director must demand payment by a written payment reminder, except where making a demand under the provisions of Article 38, paragraphs (1) and (2) (Advance Demand) of the Act on General Rules for National Taxes as applied mutatis mutandis pursuant to the following paragraph. In this case, the written payment reminder is to be issued within 50 days from the payment deadline, except where otherwise provided in Acts relating to national tax.

③The provisions of Article 38, paragraphs (1) and (2) of the Act on General Rules for National Taxes, Chapter IV, Section 1 (Tax Payment Grace Period) of that Act, and Article 55 (Consignment of Payment) of that Act apply mutatis mutandis to the case under paragraph (1).

④Realization of the property of a secondary taxpayer may be carried out only after the property of the taxpayer under paragraph (1) has been put up for realization, except where there is a risk that the value of that property will decrease significantly.

⑤The provisions of this Chapter do not preclude the exercise by a secondary taxpayer of a right of reimbursement against the taxpayer under paragraph (1).

Where a general partnership company or limited partnership company, or a certified public tax accountant corporation, attorney corporation, foreign law solicitor corporation, attorney-foreign law solicitor joint corporation, audit corporation, patent attorney corporation, judicial scrivener corporation, administrative scrivener corporation, social and labour insurance consultant corporation, or land and buildings investigator corporation is delinquent in national tax, and it is found that the amount to be collected will still be insufficient even if delinquent tax collection procedures are executed against its property, its members (in the case of a limited partnership company and an audit corporation, members with unlimited liability) bear secondary tax liability for the national tax relating to that delinquency. In this case, those members are jointly and severally liable.

①Where a corporation has been dissolved and has distributed or delivered its residual property without paying the national tax that is to be imposed on it or that it is to pay, only where it is found that the amount to be collected will still be insufficient even if delinquent tax collection procedures are executed against that corporation, the liquidators and the persons who received the distribution or delivery of the residual property (excluding persons subject to the application of the provisions of the preceding Article; the same applies hereinafter in this paragraph) bear secondary tax liability for the national tax relating to that delinquency; provided, however, that a liquidator is liable to the extent of the value of the property distributed or delivered, and a person who received the distribution or delivery of the residual property is liable to the extent of the value of the property received.

②Where a trust prescribed in Article 175 (Grounds for Commencement of Liquidation) of the Trust Act (Act No. 108 of 2006) has terminated and the liquidating trustee for that trust (meaning the liquidating trustee prescribed in Article 177 (Duties of Liquidating Trustee) of that Act; the same applies hereinafter in this paragraph) has provided property belonging to the trust property to residual property beneficiaries, etc. (meaning the residual property beneficiaries, etc. prescribed in Article 182, paragraph (2) (Vesting of Residual Property) of that Act; the same applies hereinafter in this paragraph) without paying the national tax that is to be imposed on that liquidating trustee or that the liquidating trustee is to pay (limited to national tax for which the obligation to pay constitutes an obligation borne by the trust property (meaning the obligation borne by the trust property prescribed in Article 2, paragraph (9) (Definitions) of that Act); the same applies hereinafter in this paragraph), only where it is found that the amount to be collected will still be insufficient even if delinquent tax collection procedures are executed against that liquidating trustee, the liquidating trustee (limited to a liquidating trustee who bears responsibility for performing the obligation to pay that national tax solely with property belonging to the trust property; hereinafter in this paragraph referred to as the "specified liquidating trustee") and the residual property beneficiaries, etc. bear secondary tax liability for the national tax relating to that delinquency; provided, however, that the specified liquidating trustee is liable to the extent of the value of the property provided, and the residual property beneficiaries, etc. are liable to the extent of the value of the property received.

①Where a delinquent taxpayer holds shares or capital contributions in a company that would fall under the company prescribed in Article 2, item (x) (Definition of Family Corporation) of the Corporation Tax Act (Act No. 34 of 1965) if that person were selected as the shareholder or member forming the basis of the determination (hereinafter referred to as a "family corporation"), and there is a reason set out in the following items with respect to those shares or capital contributions, and it is found that the national tax to be collected will still be insufficient even if delinquent tax collection procedures are executed against that person's property (excluding those shares or capital contributions), that company bears secondary tax liability for the national tax relating to that delinquency, to the extent of the value of the shares or capital contributions held (excluding those acquired one year or more before the statutory due date for tax payment of the national tax relating to that delinquency (for national tax to be paid by way of an amended return or reassessment that reduces the amount of tax by an amount equivalent to the amount of a refund of national tax under the provisions of Acts relating to national tax, and for the accessory tax and expenses for the delinquent tax collection procedure relating to that national tax, the date on which the return, reassessment, or determination that was the cause of that refund was made, and for negligence tax, the date on which the tax liability was established; the same applies hereinafter in this Chapter)).

②The value of the shares or capital contributions of the family corporation under the preceding paragraph is the amount calculated on the basis of the amount obtained by dividing the amount remaining after deducting the total amount of liabilities from the total amount of assets of that company at the time of issuing the written payment notice under Article 32, paragraph (1) (Notice to Secondary Taxpayers) by the number of those shares or capital contributions.

③The determination of whether a company is a family corporation under paragraph (1) is made according to its current condition at the time of issuing the written payment notice under Article 32, paragraph (1).

Where it is found that the amount to be collected will still be insufficient even if delinquent tax collection procedures are executed with respect to the delinquent taxpayer's national tax listed in the following items, the person specified in item (i) bears secondary tax liability for the national tax relating to that delinquency to the extent of the property from which the profits prescribed in that item arose (including property acquired through a change in that property and property acquired on the basis of these properties (hereinafter in this Article and the following Article referred to as "acquired property")), the person specified in item (ii) to the extent of the property relating to the lending prescribed in that item (including acquired property), and the person specified in item (iii) to the extent of the amount of the benefit received.

In the case where a person listed in the following items holds important property indispensable for carrying out the taxpayer's business and the income arising from that property constitutes the taxpayer's income, if the taxpayer is delinquent in paying the national tax pertaining to the business for which the property is used, and it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on that national tax, the person listed in the relevant item is to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of that property (including acquired property).

In the case where a taxpayer has transferred a business to an individual who is a relative sharing the same livelihood with the taxpayer or otherwise has a special relationship with the taxpayer, or to a controlled company (meaning a company that would fall under the company prescribed in Article 67, paragraph (2) of the Corporation Tax Act (Special Tax Rate for Specified Family Companies) if the taxpayer were selected as the shareholder or member forming the basis for the determination, and including a corporation similar thereto), in either case one specified by Cabinet Order, and the transferee carries on the same or a similar business, if the taxpayer is delinquent in paying the national tax pertaining to that business, and it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on that national tax, the transferee is to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of the value of the transferred property; provided, however, that this does not apply if the transfer was made one year or more before the statutory due date for tax payment of the national tax pertaining to the delinquency.

In the case where it is found that the amount to be collected is still insufficient even after the execution of the delinquent tax collection procedure on a delinquent taxpayer's national tax (including, where a request has been made for collection assistance by a tax treaty partner, etc. (meaning assistance, based on the provisions of a tax treaty, etc. (meaning a tax treaty, etc. as prescribed in Article 2, item (ii) (Definitions) of the Act on Special Provisions of the Income Tax Act, the Corporation Tax Act and the Local Tax Act Incidental to Enforcement of Tax Treaties, etc. (Act No. 46 of 1969)), by the treaty partner of that tax treaty, etc. (meaning a treaty partner as prescribed in Article 2, item (iii) of that Act) in the collection of a national tax subject to collection assistance (meaning a national tax subject to collection assistance as prescribed in Article 11-2, paragraph (1) (Assistance in the Collection of National Tax) of that Act); referred to as "collection assistance by a tax treaty partner, etc." in Article 153, paragraph (1), item (i) (Requirements for Suspension of Delinquent Tax Collection Procedures, etc.) and Article 187, paragraphs (1) and (2) (Penal Provisions)), collection pursuant to that request), and that insufficiency is found to be attributable to a transfer, made by the delinquent taxpayer on or after the day one year before the statutory due date for tax payment of that national tax, of the delinquent taxpayer's property for no consideration or for consideration of a remarkably low amount (excluding a transfer made for the purpose of security), a waiver of an obligation, or any other disposition that gives a benefit to a third party, as specified by Cabinet Order, a person who has acquired a right or been relieved of an obligation by those dispositions is to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of the extent to which the benefit received by those dispositions currently exists (or, if at the time of those dispositions those persons were a relative of the delinquent taxpayer or other individual who has a special relationship with the delinquent taxpayer, or a family corporation (including a corporation similar thereto) specified by Cabinet Order (referred to as "relative or other person with a special relationship" in Article 58, paragraph (1) (Procedure for Seizure of Movables, etc. in the Possession of a Third Party) and Article 142, paragraph (2), item (ii) (Authority and Methods of Search)), up to the limit of the benefit received by those dispositions).

In the case where a stock company, limited partnership company, or limited liability company that has evaded national tax, or received a refund of national tax, by deceit or other wrongful acts has not paid that national tax (including the accessory tax on it; the same applies hereinafter in this Article), when it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on that stock company, limited partnership company, or limited liability company (in the case of a limited partnership company, only where it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on the members with unlimited liability referred to in Article 33 (Secondary Tax Liability of Members of General Partnership Companies, etc.)), the officers of that stock company who engaged in that deceit or other wrongful acts, or the members with limited liability who execute the business of that limited partnership company or limited liability company (limited to the officers or members with limited liability in the case where, if those officers or members with limited liability were selected as the shareholders or members forming the basis for the determination, that stock company, limited partnership company, or limited liability company would fall under the company prescribed in Article 67, paragraph (2) of the Corporation Tax Act (Special Tax Rate for Specified Family Companies); hereinafter in this Article referred to as "specified officers, etc.") are to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of the lower of the amount of the national tax evaded or refunded by that deceit or other wrongful acts and the value of the property of that stock company, limited partnership company, or limited liability company that, on or after the time of that deceit or other wrongful acts, was transferred to the specified officers, etc. or transferred by the specified officers, etc. (excluding property transferred as a transaction specified by Cabinet Order, such as a transaction that gives rise to the amount of cost of sales, selling expenses, or general and administrative expenses pertaining to the revenue of each business year of that stock company, limited partnership company, or limited liability company and that is found, in light of the content of the transactions of that stock company, limited partnership company, or limited liability company and other circumstances, to have been carried out with the counterparty to the transaction in accordance with ordinary transaction terms).

①In the case where an association or foundation without legal personality is delinquent in paying national tax, if it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on the property belonging to it (excluding property that is regarded as legally belonging to a third party because that third party is the nominal holder), that third party is to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of the property regarded as legally belonging to that third party.

②In the case where property of an association or foundation without legal personality that is a delinquent taxpayer has been refunded or distributed (except in the case where Article 34 (Secondary Tax Liability of Liquidators, etc.) applies), if it is found that the amount to be collected is still insufficient even after the delinquent tax collection procedure has been executed on that association or foundation (including the third party prescribed in the preceding paragraph), the person who received that refund or distribution is to bear secondary tax liability for the national tax pertaining to that delinquency, up to the limit of the value of the property received; provided, however, that this does not apply if the refund or distribution was made one year or more before the statutory due date for tax payment of the national tax pertaining to the delinquency.

①If any of the following items applies, a collection official must seize the property of the delinquent taxpayer for the delinquent taxpayer's national tax:

②If, after the due date for payment of a national tax and by the day on which the 10 days prescribed in item (i) of the preceding paragraph have elapsed, a fact falling under any of the items of Article 38, paragraph (1) (Advance Demand) of the Act on General Rules for National Taxes arises with respect to a delinquent taxpayer who has received a demand, a collection official may seize the property immediately.

③In the case where paragraph (1) is applied to a secondary taxpayer or a guarantor, the term "demand letter" in that paragraph is deemed to be replaced with "written payment reminder".

①Property other than that necessary for collecting national tax may not be seized.

②If there is no prospect that the value of the property that may be seized will exceed the total amount of the expenses for the delinquent tax collection procedure pertaining to the seizure and the amounts of other national taxes, local taxes, and other claims that take priority over the national tax to be collected, that property may not be seized.

In seizing the property of a delinquent taxpayer (including a holder of property transferred as security; the same applies hereinafter except in Articles 75, 76 and 78 (Property Exempt from Seizure)), a collection official must endeavor not to harm the rights that a third party holds in that property, so long as doing so does not impede the execution of the delinquent tax collection procedure.

①Where property that is the subject of a pledge, mortgage, statutory lien (limited to a statutory lien listed in the items of Article 19, paragraph (1) (Statutory Liens for Preservation of Real Property, etc.) or the items of Article 20, paragraph (1) (Statutory Liens for Lease of Real Property, etc.); the same applies hereinafter except in this paragraph), right of retention, right of lease, or other right of a third party (excluding statutory liens other than those statutory liens; the same applies hereinafter) has been seized, that third party may, by the date of the public auction notice for that property (or, where it is to be sold by private contract, the date of that sale), request the district director to substitute the seizure, on the ground that the delinquent taxpayer has other property that is easy to realize and is not the subject of rights of other third parties, and that the entire amount of the delinquent taxpayer's national tax can be collected from that property.

②When a request under the preceding paragraph is made, the district director is to substitute the seizure if the district director finds the request appropriate, and must notify that third party to that effect if the district director does not find the request appropriate.

③Where notice under the preceding paragraph has been given, and the third party who received the notice has, by the day on which seven days have elapsed counting from the day of receiving the notice, applied for the realization of the property that the third party requested be seized under the provisions of paragraph (1), the property subject to the third party's right prescribed in that paragraph may not be realized unless that property has been seized and put up for realization, except where that property is extremely difficult to realize or is subject to the right of another third party.

④In the case under the preceding paragraph, if the district director does not seize the property relating to the application and put it up for realization within two months from the day of the application under that paragraph, the district director must release the seizure of the property subject to the third party's right prescribed in paragraph (1); provided, however, that this does not apply where a provision of an Act relating to national tax under which realization may not be carried out is applicable.

⑤The seizure under paragraph (2) or the preceding paragraph may be carried out notwithstanding any provision of an Act relating to national tax under which the execution of the delinquent tax collection procedure may not be newly carried out.

①When seizing the property of an heir for the national tax of the decedent, a collection official must endeavor to seize the inherited property first, to the extent that doing so does not hinder the execution of the delinquent tax collection procedure.

②Where the heir's own property has been seized for the national tax of the decedent, the heir may request the district director to substitute the seizure, on the ground that the heir holds other inherited property that is easy to realize and is not subject to the rights of third parties, and that the entire amount of that national tax can be collected from that property.

③When a request under the preceding paragraph is made, the district director is to substitute the seizure if the district director finds the request appropriate, and must notify that heir to that effect if the district director does not find the request appropriate. In this case, the provisions of paragraph (5) of the preceding Article apply mutatis mutandis.

①The effect of seizure extends to natural fruits arising from the property that has been seized (hereinafter referred to as "seized property"); provided, however, that where the delinquent taxpayer or a third party is able to use or derive profit from the seized property, this does not apply to natural fruits arising from that property (excluding natural fruits not collected by the time of the transfer of rights through the realization of the property).

②The effect of seizure does not extend to legal fruits arising from seized property; provided, however, that this does not apply to interest after the seizure in the case where a claim has been seized.

The provisions of Article 15 (Security Provisional Registration in Cases of Compulsory Auction, etc.) of the Act on Contract for Establishment of Security Interests by Use of Provisional Registration (including as applied mutatis mutandis pursuant to Article 20 (Application Mutatis Mutandis to Contracts Concerning Rights Other Than Ownership of Land, etc.) of that Act) apply mutatis mutandis to the case where property with a provisional registration for security has been seized. In this case, the phrase "that decision" in Article 15 of that Act is deemed to be replaced with "that seizure", and the phrase "is based on a petition" is deemed to be replaced with "is one".

①Where seized property is covered by non-life insurance, or is the subject of mutual aid under Article 9-7-2, paragraph (1) (Fire Mutual Aid Business) of the Small and Medium-Sized Enterprise Cooperatives Act (Act No. 181 of 1949) or other similar mutual aid under the provisions of an Act, the effect of the seizure extends to the right to receive payment of insurance proceeds or mutual aid proceeds; provided, however, that the seizure cannot be asserted against the insurer or the mutual aid business operator unless notice that the property has been seized is given to them.

②Where a collection official has received payment of the insurance proceeds or mutual aid proceeds under the preceding paragraph relating to the seizure, and the property was the subject of a statutory lien, pledge, or mortgage at the time the accident relating to that insurance or mutual aid occurred, the holder of the statutory lien, the pledgee, or the mortgagee is deemed to have made the seizure before the payment, for the purpose of applying the proviso to Article 304, paragraph (1) (Subrogation of Statutory Lien) of the Civil Code and other provisions that require the seizure of the right to receive payment of the insurance proceeds or mutual aid proceeds before the payment in order to exercise those rights.

When a collection official has seized the property of a delinquent taxpayer, the official must prepare a seizure record and, where the property is any of the following, deliver a certified copy of it to the delinquent taxpayer.

When property listed in the following items has been seized, the district director must notify those who are known among the persons listed in the relevant item to that effect and of other necessary particulars.

①Seizure of movables or securities is carried out by a collection official taking possession of the property.

②The effect of the seizure under the preceding paragraph arises at the time the collection official takes possession of the property.

③When a collection official has seized money, the national tax relating to the seizure is deemed to have been collected from the delinquent taxpayer to that extent.

①When securities have been seized, the collection official may collect the monetary claim relating to those securities.

②When a collection official has collected money under the provisions of the preceding paragraph, the national tax relating to the seizure is deemed to have been collected from the delinquent taxpayer to that extent.

①Movables or securities of a delinquent taxpayer that are in the possession of a third party other than a relative or other person with a special relationship cannot be seized if that third party refuses to deliver them.

②Where there are movables or securities under the preceding paragraph and the third party under that paragraph refuses to deliver them, the district director may, only where it is found that the delinquent taxpayer has no other property that is easy to realize and from which the entire amount of the national tax relating to the delinquency can be collected, order the third party under that paragraph in writing, designating a time limit, to deliver the movables or securities to a collection official. In this case, the district director who gave the order must notify the delinquent taxpayer to that effect.

③When the movables or securities relating to the order under the preceding paragraph have been delivered to a collection official, or when the third party who received the order under that paragraph does not deliver them to a collection official by the designated time limit, the collection official may, notwithstanding the provisions of paragraph (1), seize those movables or securities.

①Where a third party who has been ordered to deliver movables under the provisions of paragraph (2) of the preceding Article holds possession of the movables relating to the order on the basis of a right of lease, right of loan for use, or other right to use or take profits from movables under a contract with the delinquent taxpayer, and the purpose of the possession can no longer be achieved by delivering them, that third party may cancel the contract that is the basis of the possession. In this case, with respect to the claim for damages that the third party acquires against the delinquent taxpayer by the cancellation of that contract, the third party may receive distribution from the remainder of the proceeds of the sale of the movables.

②When a request is made by a third party who has been ordered to deliver movables under the provisions of paragraph (2) of the preceding Article, a collection official must, except where that third party has cancelled the contract under the provisions of the first sentence of the preceding paragraph, allow that third party to use or take profits from the movables within the term of the contract that is the basis of the possession of the movables (where that term ends later than the day on which three months have elapsed from the day the movables were seized, until that day).

③Where a third party who has been ordered to deliver movables under the provisions of paragraph (2) of the preceding Article holds possession of them on the basis of a lease contract, cancels that contract under the provisions of the first sentence of paragraph (1), and has paid rent for the subsequent period before the time of the order under paragraph (2) of the preceding Article, the third party may request the district director to distribute, from the proceeds of the sale of the movables, an amount equivalent to that rent for the period after the date of seizure under the provisions of paragraph (3) of that Article (where that amount exceeds the amount equivalent to three months' worth, that amount). In this case, notwithstanding the provisions of Article 8 (Principle of Priority of National Tax), the amount for which distribution has been requested may be distributed as ranking next after the expenses for the delinquent tax collection procedure relating to that delinquent tax collection procedure and next after the claim secured by the right of retention over those movables.

④The provisions of the preceding three paragraphs apply mutatis mutandis to a third party prescribed in paragraph (1) of the preceding Article who has not refused to deliver the movables prescribed in that paragraph.

①When a collection official finds it necessary, the official may have seized movables or securities kept in custody by the delinquent taxpayer or a third party in possession of the property. However, when having a third party keep them in custody, the official must obtain that person's consent, except where transporting them is difficult.

②Where the delinquent taxpayer or a third party has been made to keep property in custody under the provisions of the preceding paragraph, the effect of the seizure arises, notwithstanding the provisions of Article 56, paragraph (2) (Time of Taking Effect of Seizure of Movables, etc.), at the time the fact of seizure is indicated by a seal, a public notice, or other method that makes the seizure clear.

①When having a delinquent taxpayer keep seized movables in custody under the provisions of paragraph (1) of the preceding Article, a collection official may permit the use of or the taking of profits from them if the official finds that doing so poses no hindrance to the collection of national tax.

②The provisions of the preceding paragraph apply mutatis mutandis to the case where a third party who holds a right to use or take profits from seized movables is made to keep those movables in custody.

①Seizure of a claim (excluding an electronically recorded monetary claim prescribed in Article 2, paragraph (1) (Definitions) of the Electronically Recorded Monetary Claims Act (hereinafter referred to in the following Article as an "electronically recorded monetary claim"); the same applies hereinafter in this Article) is carried out by serving a written notice of seizure of a claim on the third-party debtor.

②When seizing a claim, a collection official must prohibit the obligor from performing it and prohibit the delinquent taxpayer from collecting the claim or otherwise disposing of it.

③The effect of the seizure under paragraph (1) arises at the time the written notice of seizure of a claim is served on the third-party debtor.

④When the district director has seized a claim the transfer of which requires registration, the district director must commission the relevant authority to register the seizure.

①Seizure of an electronically recorded monetary claim is carried out by serving a written notice of seizure of a claim on the third-party debtor and on the electronic monetary claim recording institution that keeps the electronic record of that electronically recorded monetary claim (meaning the electronic monetary claim recording institution prescribed in Article 2, paragraph (2) (Definitions) of the Electronically Recorded Monetary Claims Act; the same applies hereinafter in this Article).

②When seizing an electronically recorded monetary claim, a collection official must prohibit the third-party debtor from performing it, prohibit the electronic monetary claim recording institution from making the electronic record relating to the electronically recorded monetary claim, and prohibit the delinquent taxpayer from collecting the electronically recorded monetary claim or otherwise disposing of it, or from requesting an electronic record.

③The effect of the seizure under paragraph (1) arises at the time the written notice of seizure of a claim is served on the electronic monetary claim recording institution; provided, however, that the effect of the seizure under that paragraph against the third-party debtor arises at the time the written notice of seizure of a claim is served on the third-party debtor.

When seizing a claim, a collection official must seize the whole amount; provided, however, that if the official finds it unnecessary to seize the whole amount, the official may seize a part of it.

When a claim secured by a mortgage, or by a pledge or statutory lien that can be registered, has been seized, the district director may commission the relevant authority to register the seizure of the claim. In this case, the district director who has made the commission must notify the right holders (excluding the third-party debtor) of the property on which the mortgage or pledge is established or the property over which the statutory lien exists that the seizure has been made.

When necessary for the seizure of a claim, a collection official may take up the instrument relating to the claim. In this case, the provisions of Article 56, paragraph (1) (Procedures for Seizure of Movables, etc.) and Article 58 (Procedures for Seizure of Movables, etc. in the Possession of a Third Party) apply mutatis mutandis.

The effect of the seizure of a claim to salary or a pension, or to continuing income similar to these, extends to the amounts to be received after the seizure, up to the amount of the national tax to be collected.

①A collection official may collect a seized claim.

②When what has been collected under the provisions of the preceding paragraph is something other than money, a collection official must seize it.

③When a collection official has collected money under the provisions of paragraph (1), the national tax relating to the seizure is deemed to have been collected from the delinquent taxpayer to that extent.

④The provisions of Article 55, paragraphs (1) through (3) (Consignment of Payment) of the Act on General Rules for National Taxes apply mutatis mutandis where, in making the collection under paragraph (1), the third-party debtor intends to consign the performance of the claim to a collection official; provided, however, that if the time limit for collecting the securities falls after the due date for performance of the seized claim, the third-party debtor must obtain the approval of the delinquent taxpayer.

①The seizure of real property (including superficies rights and other real rights whose object is real property (excluding ownership), factory foundations, mining rights and other property that is deemed to be real property or to which the provisions on real property apply mutatis mutandis, and railway foundations, tramway foundations and canal foundations; the same applies hereinafter) is effected by serving a seizure document on the delinquent taxpayer.

②The effect of the seizure under the preceding paragraph arises at the time the seizure document is served on the delinquent taxpayer.

③When the district director has seized real property, the district director must commission the relevant authority to register the seizure.

④If the registration of the seizure under the preceding paragraph is made before the service of the seizure document, the effect of the seizure arises at the time the registration of the seizure is made, notwithstanding the provisions of paragraph (2).

⑤The effect of the seizure of a mining right arises at the time the registration of the seizure is made, notwithstanding the provisions of paragraph (2) and the preceding paragraph.

①A delinquent taxpayer may use or profit from seized real property in accordance with its ordinary use; provided, however, that the district director may restrict that use or profit only where it is found that an act that would significantly diminish the value of the real property is to be committed.

②The provisions of the preceding paragraph apply mutatis mutandis to a third party who has the right to use or profit from the seized real property.

①The provisions of Article 68, paragraphs (1) through (4) (Procedures for Seizure of Real Property and Time of Taking Effect) apply mutatis mutandis to the seizure of a registered ship or an airplane or rotorcraft registered under the provisions of the Civil Aeronautics Act (Act No. 231 of 1952) (the former hereinafter referred to as a "ship" and the latter as "aircraft").

②When necessary for a delinquent tax collection procedure, the district director may order a ship or aircraft to be temporarily anchored; provided, however, that this does not apply to a ship or aircraft that is under way.

③When necessary for a delinquent tax collection procedure, a collection official may take the necessary measures for the custody and preservation of a ship or aircraft.

④If the measures under the preceding paragraph are taken before the service of the seizure document, the effect of the seizure arises at the time the measures are taken, notwithstanding the provisions of Article 68, paragraph (2) as applied mutatis mutandis in paragraph (1).

⑤Where the district director has seized a ship or aircraft that is anchored, or has caused a ship or aircraft to be anchored under the provisions of paragraph (2), and there are business necessity or other reasonable grounds, the district director may permit it to proceed, upon application by the delinquent taxpayer, a person who has made a request for share distribution with respect to it, or a person who holds a mortgage or other right over it.

①The provisions of Article 68, paragraphs (1) through (4) (Procedures for Seizure of Real Property and Time of Taking Effect) apply mutatis mutandis to the seizure of a motor vehicle registered under the provisions of the Road Transport Vehicle Act (Act No. 185 of 1951) (hereinafter referred to as a "motor vehicle"), construction machinery registered under the provisions of the Construction Machinery Hypothecation Act (Act No. 97 of 1954) (hereinafter referred to as "construction machinery"), or a small vessel registered under the provisions of the Act on Registration, etc. of Small-Sized Vessels (Act No. 102 of 2001) (hereinafter referred to as a "small vessel").

②The provisions of paragraphs (3) and (4) of the preceding Article apply mutatis mutandis to the seizure of motor vehicles, construction machinery or small vessels.

③If the district director has seized a motor vehicle, construction machinery or a small vessel, the district director may order the delinquent taxpayer to deliver it and have a collection official take possession of it.

④The provisions of Article 56, paragraph (1) (Procedures for Seizure of Movables, etc.), Article 58 (Procedures for Seizure of Movables, etc. in the Possession of a Third Party) and Article 59 (Protection of the Rights of Third Parties, etc. Who Have Received an Order for Delivery) apply mutatis mutandis where a collection official is made to take possession of a motor vehicle, construction machinery or a small vessel under the provisions of the preceding paragraph.

⑤A collection official may have a motor vehicle, construction machinery or a small vessel of which the official has taken possession under the provisions of paragraph (3) kept in custody by the delinquent taxpayer or by a third party in possession of it. In this case, the collection official must make clear, by sealing or other means of public notice, that the motor vehicle, construction machinery or small vessel is in the possession of the collection official, and, except where the operation of the motor vehicle, the use of the construction machinery or the navigation of the small vessel is permitted under the provisions of the following paragraph, must take appropriate measures to prevent their operation, use or navigation.

⑥Where there is a business necessity or other reasonable grounds regarding a motor vehicle, construction machinery or small vessel of which a collection official has taken possession, or which the official has had kept in custody, under the provisions of paragraph (3) or the preceding paragraph, the collection official may permit its operation, use or navigation upon the application of the delinquent taxpayer and of the persons who have made a request for share distribution with respect to it and the persons who hold a mortgage or other right over it.

①Of the property not subject to the provisions of the preceding three Subsections (hereinafter referred to as "incorporeal property, etc."), the seizure of patent rights, copyrights and other property for which there is no third-party debtor, etc. is effected by serving a seizure document on the delinquent taxpayer.

②The effect of the seizure under the preceding paragraph arises at the time the seizure document is served on the delinquent taxpayer.

③When the district director has seized incorporeal property, etc. for which registration is required for the transfer of the right, the district director must commission the relevant authority to register the seizure.

④If the registration of the seizure under the preceding paragraph is made before the service of the seizure document, the effect of the seizure arises at the time the registration of the seizure is made, notwithstanding the provisions of paragraph (2).

⑤The effect of the seizure of a patent right, utility model right or other right for which a restriction on its disposition does not take effect unless it is registered arises at the time the registration of the seizure is made, notwithstanding the provisions of paragraph (2) and the preceding paragraph.

①The seizure of telephone subscription rights, the equity interest of a member of a general partnership company, and other property for which there is a third-party debtor, etc., among incorporeal property, etc. (excluding corporate bonds, etc. prescribed in Article 2, paragraph (1) (Definitions) of the Act on Book-Entry Transfer of Corporate Bonds and Shares (Act No. 75 of 2001) the attribution of rights to which is determined by entries or records in the transfer account book (referred to as "book-entry corporate bonds, etc." in the following Article)) is effected by serving a written notice of seizure on the third-party debtor, etc.

②The effect of the seizure under the preceding paragraph arises at the time the written notice of seizure is served on the third-party debtor, etc.

③The provisions of paragraphs (3) and (4) of the preceding Article apply mutatis mutandis to the seizure of property prescribed in paragraph (1) for which registration is required for the transfer of the right (excluding that prescribed in the following paragraph). In this case, the term "seizure document" in paragraph (4) of that Article is deemed to be replaced with "written notice of seizure".

④The provisions of paragraph (5) of the preceding Article apply mutatis mutandis to the seizure of an exclusive license on a patent right, or any other right, for which a restriction on its disposition does not take effect unless it is registered.

⑤The provisions of Article 65 (Taking Up of Instruments Evidencing a Claim) and Article 67 (Collection of Seized Claims) apply mutatis mutandis to the property prescribed in paragraph (1).

①The seizure of book-entry corporate bonds, etc. is effected by serving a written notice of seizure on the issuer of the book-entry corporate bonds, etc. (hereinafter in this paragraph and the following paragraph referred to as the "issuer") and the book-entry transfer institution, etc. prescribed in Article 2, paragraph (5) (Definitions) of the Act on Book-Entry Transfer of Corporate Bonds and Shares with which the delinquent taxpayer has had an account opened (where the delinquent taxpayer has made a demand set out in one of the following items and the book-entry corporate bonds, etc. relating to that demand are entered or recorded in the purchase account specified in that item, and the book-entry corporate bonds, etc. relating to that demand are to be seized, the book-entry transfer institution, etc. with which the issuer has had that purchase account opened; hereinafter referred to as the "book-entry transfer institution, etc." in this Article).

②When seizing book-entry corporate bonds, etc., a collection official must prohibit the issuer from performing its obligations with respect to them, the book-entry transfer institution, etc. from transferring or deleting them, and the delinquent taxpayer from collecting or otherwise disposing of them or from applying for their transfer or deletion.

③The seizure under paragraph (1) takes effect when the written notice of seizure is served on the book-entry transfer institution, etc.

④The provisions of Article 67 (Collection of Seized Claims) apply mutatis mutandis to book-entry corporate bonds, etc.

①If the district director has seized the equity interest of a delinquent taxpayer who is a member or other constituent of a corporation, such as an enterprise cooperative under the Small and Medium-Sized Enterprise Cooperatives Act or a shinkin bank, in which a constituent holding an equity interest, such as a member, may withdraw voluntarily (where prior notice or other fixed procedures are required for withdrawal, voluntarily after completing them) (excluding general partnership companies, limited partnership companies, and limited liability companies; hereinafter referred to as a "cooperative, etc." in this Article), and there is a ground set out below with respect to that equity interest, and it is found that, even if delinquent tax collection procedures are executed on property other than that equity interest, the national tax to be collected would still be insufficient, the district director may request the cooperative, etc. to refund part of that equity interest (or, for an equity interest the transfer of which to the cooperative, etc. is permitted, to take it over).

②The request prescribed in the preceding paragraph may be made only after prior notice has been given to the cooperative, etc. 30 days in advance (or, for withdrawal from a cooperative, etc. that requires, under the provisions of an Act or the articles of incorporation, prior notice to the cooperative, etc. a fixed period in advance that differs from this, that period).

①The following property may not be seized:

②The provisions of item (i) of the preceding paragraph (limited to the part pertaining to tatami mats and fittings) and item (xiii) of that paragraph do not apply when the property prescribed in those provisions is seized together with the building or other structure.