①A person dissatisfied with a disposition under the national tax laws that is listed in any of the following items may file the appeal specified in that item:

②A person dissatisfied with a disposition made by a district director under the national tax laws, of which the person was notified by a document stating that the investigation of the matters concerning the disposition was conducted by an official listed in one of the following items, may, deeming the disposition to have been made by the regional commissioner or the Commissioner of the National Tax Agency specified in that item, respectively, file, for a disposition deemed to have been made by a regional commissioner, any one of a request for reinvestigation to that regional commissioner or a request for review to the President of the National Tax Tribunal that the person dissatisfied with the disposition chooses, and, for a disposition deemed to have been made by the Commissioner of the National Tax Agency, a request for review to the Commissioner of the National Tax Agency.

③If a determination has been made on a request for reinvestigation under paragraph (1), item (i), (a) or the preceding paragraph (limited to the part concerning item (i)) (excluding a request filed after the expiry of the statutory period for requesting reinvestigation or any other request that has not been lawfully filed; the same applies in the following paragraph), and the person who filed the request for reinvestigation is still dissatisfied with the disposition as it stands after that determination, that person may file a request for review with the President of the National Tax Tribunal.

④A person who has filed a request for reinvestigation under paragraph (1), item (i), (a) or paragraph (2) (limited to the part concerning item (i)) may, in any of the following cases, file a request for review with the President of the National Tax Tribunal concerning the disposition to which the request for reinvestigation pertains, without going through a determination:

⑤If a person is dissatisfied with a disposition under the national tax laws made by an official of the National Tax Agency, a Regional Taxation Bureau, a tax office or a customs house, the provisions of paragraph (1) apply by deeming the disposition to have been made by the head of the National Tax Agency, Regional Taxation Bureau, tax office or customs house to which that official belongs, respectively.

①The provisions of the preceding Article do not apply to the following dispositions:

②The provisions of Article 3 (Request for Review of Inaction) of the Administrative Complaint Review Act do not apply to inaction concerning a disposition under this Section or any other disposition to be made with regard to an appeal.

①An appeal (excluding a request for review under Article 75, paragraphs (3) and (4) (Request for Review after a Request for Reinvestigation); the same applies in paragraph (3)) may not be filed once three months have elapsed counting from the day following the day on which the person became aware that the disposition had been made (or, if the person received a notice concerning the disposition, the day on which the person received it); provided, however, that this does not apply if there is a justifiable reason.

②A request for review under Article 75, paragraph (3) may not be filed once one month has elapsed counting from the day following the day on which a certified copy of the written determination on reinvestigation was served under Article 84, paragraph (10) (Procedures for Determinations, etc.); provided, however, that this does not apply if there is a justifiable reason.

③An appeal may not be filed once one year has elapsed counting from the day following the day on which the disposition was made; provided, however, that this does not apply if there is a justifiable reason.

④The provisions of Article 22 (Time of Submission of Tax Returns, etc. Sent by Mail, etc.) apply mutatis mutandis to a written request for reinvestigation or a written request for review concerning an appeal.

The Commissioner of the National Tax Agency, the President of the National Tax Tribunal, a regional commissioner, a district director or a director-general of a customs house must endeavor to establish a standard period normally required from the time an appeal arrives at their office until a determination or decision is made on the appeal, and, when they have established such a period, must make it public by keeping it available at that office or by other appropriate means.

①The National Tax Tribunal is the organ that makes decisions on requests for review concerning dispositions under the national tax laws (excluding a request for review under Article 75, paragraph (1), item (ii) and paragraph (2) (limited to the part concerning item (ii)) (Appeals against Dispositions Concerning National Tax); the same applies in Subsection 3 (Requests for Review)).

②The head of the National Tax Tribunal is the President of the National Tax Tribunal, who is appointed by the Commissioner of the National Tax Agency with the approval of the Minister of Finance.

③Branches are established in the required locations to handle part of the affairs of the National Tax Tribunal.

④One of the National Tax Tribunal judges working at each branch referred to in the preceding paragraph is to be the chief National Tax Tribunal judge. The chief National Tax Tribunal judge oversees the affairs of that branch.

⑤Necessary matters concerning the organization and operation of the National Tax Tribunal are specified by Cabinet Order, and the names and locations of the branches are specified by Ministry of Finance Order.

①National Tax Tribunal judges and assistant National Tax Tribunal judges are assigned to the National Tax Tribunal.

②National Tax Tribunal judges investigate and examine cases concerning requests for review filed with the President of the National Tax Tribunal, and assistant National Tax Tribunal judges, under the orders of National Tax Tribunal judges, process those affairs.

③An assistant National Tax Tribunal judge designated by the President of the National Tax Tribunal may perform the duties of a National Tax Tribunal judge; provided, however, that this does not apply to duties that this Act assigns to the presiding tribunal judge.

④The qualifications for National Tax Tribunal judges are specified by Cabinet Order.

①Appeals against dispositions under the national tax laws (excluding a request for review prescribed in the following paragraph) are governed by the Administrative Complaint Review Act (excluding Chapters II and III (Procedures for Appeals)), except as otherwise provided in this Section or other national tax laws.

②Requests for review under Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part concerning item (ii)) (Appeals against Dispositions Concerning National Tax) are governed by the Administrative Complaint Review Act, except as otherwise provided in this Section (excluding the following Subsection and Subsection 3 (Requests for Review)) or other national tax laws.

③Appeals against dispositions under the provisions of Chapter II (Liquor Manufacturing Licenses and Liquor Sales Business Licenses, etc.) of the Liquor Tax Act are governed by the Administrative Complaint Review Act, and the provisions of this Section do not apply to them.

①A request for reinvestigation must be filed by submitting a document stating the following matters:

②In addition to the matters prescribed in the preceding paragraph, the document referred to in that paragraph (hereinafter referred to as a "written request for reinvestigation") must, if the request for reinvestigation is filed after the expiry of the period prescribed in Article 77, paragraph (1) or (3) (Period for Filing Appeals), state the justifiable reason prescribed in the proviso to paragraph (1) or the proviso to paragraph (3) of that Article.

③If a written request for reinvestigation violates the provisions of the preceding two paragraphs or Article 124 (Statement of Name, Domicile and Identification Number of Person Submitting Documents), the district director or other head of an administrative organ with which the request for reinvestigation has been filed (hereinafter referred to as the "reinvestigation authority") must set a reasonable period and require that the deficiency be corrected within that period. In this case, if the deficiency is minor, the reinvestigation authority may correct it ex officio.

④When required to make the correction referred to in the preceding paragraph, a requester for reinvestigation may also make it by appearing at the tax office or other administrative organ to which the request for reinvestigation pertains, stating the matters to be corrected, and confirming a document in which an official of that administrative organ has recorded the content of the statement.

⑤In the case referred to in paragraph (3), if the requester for reinvestigation does not correct the deficiency within the period referred to in that paragraph, or if it is clear that the request for reinvestigation is unlawful and cannot be corrected, the reinvestigation authority may, without going through the review proceedings prescribed in Article 84, paragraphs (1) through (6) (Procedures for Determinations, etc.), dismiss the request for reinvestigation without prejudice by a determination under Article 83, paragraph (1) (Determinations).

①A request for reinvestigation under Article 75, paragraph (2) (limited to the part concerning item (i)) (Request for Reinvestigation of a Disposition Based on an Investigation by Officials of a Regional Taxation Bureau) may also be filed via the district director who made the disposition to which the request for reinvestigation pertains. In this case, the requester for reinvestigation is to file it by submitting the written request for reinvestigation to that district director.

②In the case referred to in the preceding paragraph, the district director referred to in that paragraph must immediately send the written request for reinvestigation to the regional commissioner having jurisdiction over the district under that district director's jurisdiction.

③In calculating the period for requesting reinvestigation in the case referred to in paragraph (1), the request for reinvestigation is deemed to have been filed at the time the written request for reinvestigation was submitted to the district director referred to in that paragraph.

①If a request for reinvestigation has been filed after the expiry of the statutory period or is otherwise unlawful, the reinvestigation authority dismisses the request for reinvestigation without prejudice by a determination.

②If a request for reinvestigation is groundless, the reinvestigation authority dismisses the request for reinvestigation with prejudice by a determination.

③If a request for reinvestigation is well-grounded, the reinvestigation authority, by a determination, revokes the disposition to which the request for reinvestigation pertains in whole or in part, or changes it; provided, however, that the disposition may not be changed to the disadvantage of the requester for reinvestigation.