A 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:

A 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.

If 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.

A 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:

If 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.

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

The 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.

An 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.

A 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.

An 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.

The 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.

The 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)).

The 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.

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

One 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.

Necessary 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.

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

National 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.

An 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.

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

Appeals 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.

Requests 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.

Appeals 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.

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

In 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.

If 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.

When 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.

In 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).

A 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.

In 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.

In 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.

If 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.

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

If 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.

If the requester for reinvestigation or an intervenor (meaning an intervenor prescribed in Article 109, paragraph (3) (Intervenors); the same applies hereinafter in this Subsection and the following Subsection) so petitions, the reinvestigation authority must give the person who made the petition (hereinafter referred to as the "petitioner" in this Article) an opportunity to state an opinion orally on the case concerning the request for reinvestigation; provided, however, that this does not apply if it is found to be difficult to give that opportunity because of the whereabouts of the petitioner or other circumstances.

The statement of opinion under the main clause of the preceding paragraph (hereinafter referred to as an "oral statement of opinion" in this Article) is to be made by the reinvestigation authority designating the date and place and summoning the requester for reinvestigation and the intervenors.

At an oral statement of opinion, the petitioner may appear together with an assistant, with the permission of the reinvestigation authority.

If it finds it necessary, the reinvestigation authority may have an official of its administrative organ hear an oral statement of opinion.

At an oral statement of opinion, the reinvestigation authority or the official referred to in the preceding paragraph may restrict a statement made by the petitioner if it extends to matters unrelated to the case or is otherwise inappropriate.

The requester for reinvestigation or an intervenor may submit documentary evidence or physical evidence. In this case, if the reinvestigation authority has set a reasonable period within which the documentary evidence or physical evidence is to be submitted, it must be submitted within that period.

A determination on a request for reinvestigation must be made by means of a written determination on reinvestigation that states the main text and the reasons and bears the name and seal of the reinvestigation authority.

If a determination on a request for reinvestigation upholds all or part of the disposition to which the request for reinvestigation pertains, the reasons referred to in the preceding paragraph must make clear the reasons for which the upheld disposition is justified.

The reinvestigation authority must state in the written determination on reinvestigation referred to in paragraph (7) (excluding one for a determination revoking the whole of the disposition to which the request for reinvestigation pertains) that a request for review may be filed with the President of the National Tax Tribunal concerning the disposition to which the request for reinvestigation pertains (or, for a determination of dismissal without prejudice, that a request for review may be filed only if that determination of dismissal without prejudice is unlawful), as well as the period for requesting reconsideration, and thereby inform the recipient of these.

A determination on a request for reinvestigation takes effect when a certified copy of the written determination on reinvestigation is served on the requester for reinvestigation (or, for a determination under paragraph (3) of the preceding Article in the case where the request for reinvestigation was filed by a person other than the person to whom the disposition was addressed, on the requester for reinvestigation and the person to whom the disposition was addressed).

The reinvestigation authority must send a certified copy of the written determination on reinvestigation to the intervenors.

When it has made a determination on a request for reinvestigation, the reinvestigation authority must promptly return the documentary evidence or physical evidence submitted under paragraph (6) to the persons who submitted it.

If, after a disposition by a district director, a regional commissioner or a director-general of a customs house (hereinafter referred to as a "district director of the tax office, etc." in this Article and the following Article) concerning income tax, corporation tax, local corporation tax, inheritance tax, gift tax, land value tax, consumption tax on the transfer, etc. of a taxable asset, tax for promotion of power-resources development or international tourist tax (excluding international tourist tax payable under Article 18, paragraph (1) (Payment by International Tourist Passengers, etc.) of the International Tourist Tax Act; the same applies in paragraph (1) of the following Article) (excluding a disposition concerning the collection of national tax and a delinquent tax collection procedure (including a disposition conducted in accordance with the rules for that procedure)), or a notice of tax payment under Article 36, paragraph (1) (Notice of Tax Payment) that pertains to item (i) of that paragraph (limited to the part concerning penalty tax for failure to pay and heavy penalty tax under Article 68, paragraph (3) or (4) (limited to the part concerning the heavy penalty tax under paragraph (3) of that Article) (Heavy Penalty Tax)) or item (ii) of that paragraph (hereinafter simply referred to as a "disposition" in this Article and paragraph (1) of the following Article), the place for tax payment changes, with the result that the district director of the tax office, etc. having jurisdiction over the place for tax payment at the time of the disposition differs from the district director of the tax office, etc. having jurisdiction over the place for tax payment at the time a request for reinvestigation concerning the disposition is filed under Article 75, paragraph (1), item (i), (a) or paragraph (2) (limited to the part concerning item (i)) (Appeals against Dispositions Concerning National Tax) (hereinafter referred to as the "current place for tax payment" in this Article), the request for reinvestigation must, notwithstanding those provisions, be filed with the district director of the tax office, etc. having jurisdiction over the current place for tax payment. In this case, the disposition is deemed to have been made by the district director of the tax office, etc. having jurisdiction over the current place for tax payment.

A person who files a request for reinvestigation under the preceding paragraph must add to the written request for reinvestigation the name of the tax office, Regional Taxation Bureau or customs house to which the disposition pertains.

In the case referred to in paragraph (1), if the written request for reinvestigation is submitted to the district director of the tax office, etc. to which the disposition pertains, that district director of the tax office, etc. may accept the written request for reinvestigation. In this case, the written request for reinvestigation is deemed to have been submitted to the district director of the tax office, etc. having jurisdiction over the current place for tax payment.

The district director of the tax office, etc. that has accepted the written request for reinvestigation referred to in the preceding paragraph must send that written request for reinvestigation to the district director of the tax office, etc. having jurisdiction over the current place for tax payment, and notify the requester for reinvestigation to that effect.

If a request for reinvestigation has been filed concerning a disposition by a district director of the tax office, etc. concerning income tax, corporation tax, local corporation tax, inheritance tax, gift tax, land value tax, consumption tax on the transfer, etc. of a taxable asset, tax for promotion of power-resources development or international tourist tax, and the place for tax payment for the national tax to which the disposition pertains changes, with the result that the district director of the tax office, etc. with which the request for reinvestigation has been filed differs from the district director of the tax office, etc. having jurisdiction over the new place for tax payment, the district director of the tax office, etc. with which the request for reinvestigation has been filed may, upon petition by the requester for reinvestigation or ex officio, transfer the case concerning the request for reinvestigation to the district director of the tax office, etc. having jurisdiction over the new place for tax payment.

When a case concerning a request for reinvestigation has been transferred under the preceding paragraph, the request for reinvestigation is deemed to have been filed from the beginning with the district director of the tax office, etc. to which the case was transferred, and that district director of the tax office, etc. makes the determination on the request for reinvestigation.

When the district director of the tax office, etc. has transferred a case concerning a request for reinvestigation under paragraph (1), it must send the written request for reinvestigation concerning that request for reinvestigation, the related documents and other articles (hereinafter referred to as the "written request for reinvestigation, etc.") to the district director of the tax office, etc. to which the case was transferred, and notify the requester for reinvestigation and the intervenors to that effect.

A request for review must, pursuant to the provisions of Cabinet Order, be filed by submitting a document stating the following matters:

In addition to the matters prescribed in the preceding paragraph, the document referred to in that paragraph (hereinafter referred to as a "written request for review" in this Subsection) must, in the cases listed in the following items, state the matters specified in those items:

The object prescribed in paragraph (1), item (iii) is to be stated so as to make clear the extent to which revocation or change of the disposition is sought, and the reasons prescribed in that item are to make clear the assertions of the requester for review against the reasons for the disposition of which the requester was notified by a written notice or other document concerning the disposition.

A request for review may also be filed via the head of the administrative organ that made the disposition to which the request for review pertains (including a determination on a request for reinvestigation concerning that disposition). In this case, the requester for review is to file it by submitting the written request for review to that head of the administrative organ.

In the case referred to in the preceding paragraph, the head of the administrative organ referred to in that paragraph must immediately send the written request for review to the President of the National Tax Tribunal.

In calculating the period for filing a request for review in the case referred to in paragraph (1), the request for review is deemed to have been filed at the time the written request for review was submitted to the head of the administrative organ referred to in that paragraph.

If a request for reinvestigation has been filed with a district director, a regional commissioner or a director-general of a customs house, and that district director, regional commissioner or director-general of the customs house finds it appropriate to treat the request for reinvestigation as a request for review and notifies the requester for reinvestigation to that effect, and the requester for reinvestigation consents to this, a request for review is deemed to have been filed with the President of the National Tax Tribunal on the day of that consent.

The document concerning the notice referred to in the preceding paragraph must state the reasons for the disposition to which the request for reinvestigation pertains, except where those reasons have been notified to the person to whom the disposition was addressed by a written notice or other document concerning the disposition.

If paragraph (1) applies, the district director, regional commissioner or director-general of the customs house with which the request for reinvestigation referred to in that paragraph has been filed must send the written request for reinvestigation, etc. to the President of the National Tax Tribunal, and notify the requester for reinvestigation and the intervenors to that effect. In this case, the written request for reinvestigation so sent is deemed to be a written request for review.

If a request for review has been filed concerning a reassessment or determination, etc. (including a notice of tax payment concerning national withholding tax; the same applies hereinafter in this Article, Article 104 (Joint Examination, etc.) and Article 115, paragraph (1), item (ii) (Appeal Prerequisite, etc.)), and a request for reinvestigation is filed with a district director, a regional commissioner or a director-general of a customs house concerning another reassessment or determination, etc. made with regard to the tax basis, etc. or tax amount, etc. (including the amount of accessory tax on the national tax; the same applies hereinafter in this Article, Article 104 and Article 115, paragraph (1), item (ii)) of the national tax to which that reassessment or determination, etc. pertains, the district director, regional commissioner or director-general of the customs house with which the request for reinvestigation has been filed must send the written request for reinvestigation, etc. to the President of the National Tax Tribunal, and notify the requester for reinvestigation to that effect.

If a request for reinvestigation has been filed with a district director, a regional commissioner or a director-general of a customs house concerning a reassessment or determination, etc., and a request for review is filed concerning another reassessment or determination, etc. made with regard to the tax basis, etc. or tax amount, etc. of the national tax to which that reassessment or determination, etc. pertains, the district director, regional commissioner or director-general of the customs house with which the request for reinvestigation has been filed must send the written request for reinvestigation, etc. to the President of the National Tax Tribunal, and notify the requester for reinvestigation and the intervenors to that effect.

If a written request for reinvestigation, etc. has been sent to the President of the National Tax Tribunal under the preceding two paragraphs, a request for review concerning the disposition to which the request for reinvestigation pertains is deemed to have been filed with the President of the National Tax Tribunal on the day on which it was sent.

The provisions of paragraph (2) of the preceding Article apply mutatis mutandis to the document concerning the notice referred to in paragraph (1) or (2), and the provisions of the second sentence of paragraph (3) of that Article apply mutatis mutandis to the case referred to in the preceding paragraph.

If a written request for review violates the provisions of Article 87 (Matters to Be Stated in a Written Request for Review, etc.) or Article 124 (Statement of Name, Domicile and Identification Number of Person Submitting Documents), the President of the National Tax Tribunal must set a reasonable period and require that the deficiency be corrected within that period. In this case, if the deficiency is minor, the President of the National Tax Tribunal may correct it ex officio.

When required to make the correction referred to in the preceding paragraph, the requester for review may also make it by appearing at the National Tax Tribunal, stating the matters to be corrected, and confirming a document in which an official of the National Tax Tribunal has recorded the content of the statement.

In the case referred to in paragraph (1) of the preceding Article, if the requester for review does not correct the deficiency within the period referred to in that paragraph, the President of the National Tax Tribunal may, without going through the review proceedings prescribed in the following Article through Article 97-4 (Review Proceedings by the Presiding Tribunal Judge, etc.), dismiss the request for review without prejudice by a decision under Article 98, paragraph (1) (Decisions).

The same as in the preceding paragraph applies if it is clear that a request for review is unlawful and cannot be corrected.

The requester for review, the intervenors and the agency that made the original disposition prescribed in paragraph (1) of the following Article (hereinafter referred to as the "parties to the proceedings"), and the presiding tribunal judge, must, in order to achieve a simple, prompt and fair examination, cooperate with one another in the examination and seek to ensure the systematic progress of the review proceedings.

When the President of the National Tax Tribunal has accepted a written request for review, the President of the National Tax Tribunal is to set a reasonable period and have the head of the administrative organ concerned with the disposition that is the subject of the request for review (or, for a disposition prescribed in 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), the relevant regional commissioner; hereinafter referred to as the "agency that made the original disposition") submit a written answer, except where the request for review is dismissed without prejudice under Article 92 (Decision of Dismissal without Prejudice Made without Going through Review Proceedings). In this case, the President of the National Tax Tribunal is to send the accepted written request for review to the agency that made the original disposition.

The written answer referred to in the preceding paragraph must state the assertions of the agency that made the original disposition in response to the object of and reasons for the request for review.

When a written answer has been submitted by the agency that made the original disposition, the President of the National Tax Tribunal must send it to the requester for review and the intervenors.

The President of the National Tax Tribunal designates one presiding tribunal judge and two or more associate tribunal judges to investigate and examine a case concerning a request for review.

The persons designated by the President of the National Tax Tribunal under the preceding paragraph must be persons other than the following:

The requester for review may submit a document stating a rebuttal to the matters stated in the written answer sent under Article 93, paragraph (3) (Sending of the Written Answer) (hereinafter referred to as a "written rebuttal" in this Article and Article 97-4, paragraph (2), item (i), (b) (Conclusion of Review Proceedings)). In this case, if the presiding tribunal judge has set a reasonable period within which the written rebuttal is to be submitted, it must be submitted within that period.

An intervenor may submit a document stating an opinion on the case concerning the request for review (hereinafter referred to as an "intervenor's written opinion" in this Article and Article 97-4, paragraph (2), item (i), (c)). In this case, if the presiding tribunal judge has set a reasonable period within which the intervenor's written opinion is to be submitted, it must be submitted within that period.

The presiding tribunal judge must send a written rebuttal submitted by the requester for review to the intervenors and the agency that made the original disposition, and an intervenor's written opinion submitted by an intervenor to the requester for review and the agency that made the original disposition, respectively.

If the requester for review or an intervenor so petitions, the presiding tribunal judge must give the person who made the petition an opportunity to state an opinion orally on the case concerning the request for review.

In making the statement of opinion under the preceding paragraph (referred to as an "oral statement of opinion" in the following paragraph and Article 97-4, paragraph (2), item (ii) (Conclusion of Review Proceedings)), the person who made the petition referred to in the preceding paragraph may, with the permission of the presiding tribunal judge, ask questions of the agency that made the original disposition concerning the case concerning the request for review.

The provisions of the proviso to Article 84, paragraph (1), and paragraphs (2), (3) and (5) of that Article (Procedures for Determinations, etc.) apply mutatis mutandis to the oral statement of opinion referred to in paragraph (1). In this case, the term "reinvestigation authority" in paragraph (2) of that Article is deemed to be replaced with "presiding tribunal judge", the phrase "the requester for reinvestigation and the intervenors" with "all parties to the proceedings", the term "reinvestigation authority" in paragraph (3) of that Article with "presiding tribunal judge", and the phrase "the reinvestigation authority or the official referred to in the preceding paragraph" in paragraph (5) of that Article with "the presiding tribunal judge".

An associate tribunal judge may, under the orders of the presiding tribunal judge, give the permission referred to in paragraph (2) and perform the acts referred to in Article 84, paragraph (5) as applied mutatis mutandis pursuant to the preceding paragraph following the deemed replacement of terms.

The requester for review or an intervenor may submit documentary evidence or physical evidence.

The agency that made the original disposition may submit documents and other articles proving the facts constituting the grounds for the disposition.

In the cases referred to in the preceding two paragraphs, if the presiding tribunal judge has set a reasonable period within which the documentary evidence or physical evidence, or the documents or other articles, are to be submitted, they must be submitted within that period.

When it is necessary for conducting the examination, the presiding tribunal judge may, upon petition by a party to the proceedings or ex officio, take the following actions:

A National Tax Tribunal judge, an assistant National Tax Tribunal judge or any other official of the National Tax Tribunal may, upon commission by or under the orders of the presiding tribunal judge, take the actions listed in item (i) or (iii) of the preceding paragraph.

When taking the actions listed in paragraph (1), items (i) and (iii), a National Tax Tribunal judge, an assistant National Tax Tribunal judge or any other official of the National Tax Tribunal must carry a certificate of identification and present it upon request by a person concerned.

If, because a requester for review, etc. (including a person having a special relationship with the requester for review that is specified by Cabinet Order) fails, without a justifiable reason, to respond to questioning, a request for submission or an inspection under paragraph (1), items (i) through (iii) or paragraph (2), it has become extremely difficult to clarify the basis for all or part of the assertions of the requester for review, etc., the President of the National Tax Tribunal may decline to adopt the assertions of the requester for review, etc. relating to that part.

The authority of the relevant officials prescribed in paragraph (1) or (2) must not be construed as being granted for the purpose of criminal investigation.

If the presiding tribunal judge finds that, because the case concerning a request for review is complex, such as by involving numerous or intricate matters to be examined, or due to other circumstances, it is necessary to conduct the review proceedings prescribed in Article 95-2 through paragraph (1) of the preceding Article (Oral Statement of Opinion, etc.) in a systematic manner in order to conduct a prompt and fair examination, the presiding tribunal judge may designate a date and place, summon the parties to the proceedings, and hear their opinions in advance on petitions concerning those review proceedings.

If the parties to the proceedings reside in a distant place or in other cases where the presiding tribunal judge finds it appropriate, the presiding tribunal judge may, pursuant to the provisions of Cabinet Order, hear the opinions referred to in the preceding paragraph by a means that enables the presiding tribunal judge and the parties to the proceedings to communicate with one another by sending and receiving voice.

When the presiding tribunal judge has heard opinions under the preceding two paragraphs, the presiding tribunal judge is to determine without delay the dates and places of the review proceedings prescribed in Article 95-2 through paragraph (1) of the preceding Article and the scheduled time for concluding the review proceedings under Article 97-4, paragraph (1) (Conclusion of Review Proceedings), and notify the parties to the proceedings of these. The same applies when the presiding tribunal judge has changed that scheduled time.

Until the review proceedings are concluded under paragraph (1) or (2) of the following Article, a party to the proceedings may request the presiding tribunal judge to allow inspection of the documents or other articles submitted under Article 96, paragraph (1) or (2) (Submission of Documentary Evidence, etc.) or Article 97, paragraph (1), item (ii) (Questioning, Inspection, etc. for Examination) (or, for an electronic or magnetic record, inspection of the matters recorded in it as displayed in the manner specified by Ministry of Finance Order), or to deliver a copy of those documents or a document stating the matters recorded in that electronic or magnetic record. In this case, the presiding tribunal judge may not refuse the inspection or delivery unless the presiding tribunal judge finds that there is a risk of harm to the interests of a third party, or there is another justifiable reason.

When the presiding tribunal judge intends to allow inspection under the preceding paragraph or to make a delivery under that paragraph, the presiding tribunal judge must hear the opinion of the person who submitted the documents or other articles subject to that inspection or delivery; provided, however, that this does not apply if the presiding tribunal judge finds it unnecessary.

The presiding tribunal judge may designate the date and time and the place for inspection under paragraph (1).

A requester for review or intervenor who receives a delivery under paragraph (1) must, pursuant to the provisions of Cabinet Order, pay a fee in the amount specified by Cabinet Order within the limits of the actual cost.

If the presiding tribunal judge finds that there is economic hardship or another special reason, the presiding tribunal judge may, pursuant to the provisions of Cabinet Order, reduce or waive the fee referred to in the preceding paragraph.

When the presiding tribunal judge finds that the necessary examination has been completed, the presiding tribunal judge is to conclude the review proceedings.

Beyond what is provided for in the preceding paragraph, the presiding tribunal judge may conclude the review proceedings if any of the following items applies:

When the presiding tribunal judge has concluded the review proceedings pursuant to the provisions of the preceding two paragraphs, the presiding tribunal judge is to promptly notify the parties to the proceedings that the review proceedings have been concluded.

If a request for review has been made after the expiration of the statutory period or is otherwise unlawful, the President of the National Tax Tribunal dismisses the request for review by a decision.

If a request for review is groundless, the President of the National Tax Tribunal rejects the request for review by a decision.

If a request for review is well-grounded, the President of the National Tax Tribunal, by a decision, revokes the disposition to which the request for review 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 review.

When making a decision (excluding where the President dismisses the request for review pursuant to the provisions of Article 92 (Decision of Dismissal Made without Review Proceedings)), the President of the National Tax Tribunal must make it based on the resolution of the presiding tribunal judge and the associate tribunal examiners.

When making a decision based on an interpretation different from the interpretation of laws and regulations indicated in a circular issued by the Commissioner of the National Tax Agency, or making a decision that is found to be an important precedent for the interpretation of laws and regulations in making dispositions concerning other national taxes, the President of the National Tax Tribunal must notify the Commissioner of the National Tax Agency of the President's opinion in advance.

In the case where notice under the preceding paragraph has been given, the Commissioner of the National Tax Agency must consult the National Tax Council on the opinion jointly with the President of the National Tax Tribunal, except where the opinion of the President of the National Tax Tribunal upholds the assertions of the requester for review and the Commissioner of the National Tax Agency finds that opinion to be reasonable.

If the President of the National Tax Tribunal has consulted the National Tax Council jointly with the Commissioner of the National Tax Agency pursuant to the provisions of the preceding paragraph, the President of the National Tax Tribunal must make the decision based on the resolution of the National Tax Council.

A decision must be made by means of a written decision stating the following matters and bearing the name and seal of the President of the National Tax Tribunal:

The provisions of Article 84, paragraph (8) (Procedures for Determinations, etc.) apply mutatis mutandis to the decision referred to in the preceding paragraph.

A decision becomes effective when a transcript of the written decision is served on the requester for review (or, in the case of a decision under the provisions of Article 98, paragraph (3) (Decisions) where the request for review was made by a person other than the addressee of the disposition, on the requester for review and the addressee of the disposition).

The President of the National Tax Tribunal must send a transcript of the written decision to the intervenors and the agency that made the original disposition (in the case of a request for review concerning a disposition prescribed in Article 75, paragraph (2) (limited to the part pertaining to item (i)) (Appeals against Dispositions concerning National Taxes), including the district director connected with that disposition).

A decision binds the relevant administrative agencies.

If a disposition made on the basis of an application or request is revoked by a decision on the grounds that the procedure was unlawful or unjust, or if a disposition dismissing or rejecting an application or request is revoked by a decision, the head of the administrative organ connected with that disposition must make a new disposition on the application or request in accordance with the purport of the decision.

If a disposition publicly notified under a law concerning national taxes is revoked or changed by a decision, the head of the administrative organ connected with that disposition must give public notice that the disposition has been revoked or changed.

If a disposition notified under a law concerning national taxes to an interested person prescribed in Article 109, paragraph (1) (Intervenors) other than the addressee of the disposition is revoked or changed by a decision, the head of the administrative organ connected with that disposition must notify the persons who received that notice (excluding the requester for review and the intervenors) that the disposition has been revoked or changed.

When the President of the National Tax Tribunal has made a decision, the President of the National Tax Tribunal must promptly return to the persons who submitted them the documentary evidence or physical evidence, or documents or other articles, submitted pursuant to the provisions of Article 96, paragraph (1) or (2) (Submission of Documentary Evidence, etc.) and the books and documents, or other articles submitted in response to a request for submission under the provisions of Article 97, paragraph (1), item (ii) (Questioning, Inspection, etc. for Review).

The reinvestigation authority, or the President of the National Tax Tribunal or the Commissioner of the National Tax Agency (hereinafter referred to as the "President of the National Tax Tribunal, etc."), may, if they find it necessary, consolidate the review proceedings for multiple appeals, or separate the review proceedings for multiple consolidated appeals.

If an appeal has been filed against a reassessment or determination, etc., and there is another reassessment or determination, etc. made with regard to the tax basis, etc. or tax amount, etc. of the national tax to which that reassessment or determination, etc. pertains, the President of the National Tax Tribunal, etc. may, beyond what is done under the provisions of the preceding paragraph, also review that other reassessment or determination, etc.; provided, however, that this does not apply if a determination or decision on an appeal has already been made with regard to that other reassessment or determination, etc.

In the case where the provisions of the preceding paragraph apply, the President of the National Tax Tribunal, etc. may, in the determination or decision on the appeal, revoke that other reassessment or determination, etc. in whole or in part.

The provisions of the preceding two paragraphs apply mutatis mutandis in the case where an appeal has been filed against a disposition in response to a request for reassessment and there is another reassessment or determination made with regard to the tax basis, etc. or tax amount, etc. of the national tax to which that request for reassessment pertains.

An appeal against a disposition under a law concerning national taxes does not preclude the effect of the disposition that is its subject, the execution of the disposition, or the continuation of procedures; provided, however, that property attached for the collection of the national tax (including the specified real property under participatory attachment prescribed in Article 89-2, paragraph (4) (Conversion into Cash by the District Director Who Made a Participatory Attachment) of the National Tax Collection Act) may not be converted into cash through a delinquent tax collection procedure (including a disposition conducted in accordance with the rules for that procedure; the same applies hereinafter in this Article) until a determination or decision on the appeal is made, except where the value of the property is likely to decrease significantly or where the appellant (or, if the appellant is not the addressee of the disposition, the appellant and the addressee of the disposition) has requested otherwise.

The reinvestigation authority or the Commissioner of the National Tax Agency may, if they find it necessary, upon the petition of the requester for reinvestigation or of a person who has made a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) (Appeals against Dispositions concerning National Taxes) (referred to as a "requester for reinvestigation, etc." in the following paragraph), or on their own authority, grant a grace period for the collection of the whole or part of the national tax connected with the disposition that is the subject of the appeal, or suspend the continuation of the delinquent tax collection procedure, or order these measures.

If a requester for reinvestigation, etc. has provided security and requested that, with regard to the national tax connected with the disposition that is the subject of the appeal, no attachment be made through a delinquent tax collection procedure or an attachment already made through a delinquent tax collection procedure be released, the reinvestigation authority or the Commissioner of the National Tax Agency may, if they find it reasonable, refrain from making that attachment or release that attachment, or order these measures.

The President of the National Tax Tribunal may, if the President of the National Tax Tribunal finds it necessary, upon the petition of the requester for review or on the President's own authority, after hearing the opinion of the regional commissioner, district director, or director-general of customs who has the authority to collect the national tax connected with the disposition that is the subject of the request for review pursuant to the provisions of Article 43 (Competent Collection Agency for National Taxes) and Article 44 (Special Provisions on the Competent Collection Agency Where Reorganization Proceedings, etc. Have Commenced) (hereinafter referred to as the "competent collection agency" in this Article), request the competent collection agency to grant a grace period for the collection of the whole or part of that national tax or to suspend the continuation of the delinquent tax collection procedure.

If the requester for review has provided security to the competent collection agency and requested that, with regard to the national tax connected with the disposition that is the subject of the request for review, no attachment be made through a delinquent tax collection procedure or an attachment already made through a delinquent tax collection procedure be released, the President of the National Tax Tribunal may, if the President of the National Tax Tribunal finds it reasonable, request the competent collection agency not to make that attachment or to release that attachment.

When the competent collection agency has been requested by the President of the National Tax Tribunal, pursuant to the provisions of paragraph (4), to grant a collection grace period or to suspend the continuation of the delinquent tax collection procedure, or, pursuant to the provisions of the preceding paragraph, not to make an attachment or to release the attachment, the competent collection agency must grant a grace period for the collection of the whole or part of the national tax connected with the disposition that is the subject of the request for review, or suspend the continuation of the delinquent tax collection procedure, or refrain from making that attachment or release that attachment.

The provisions of Article 49, paragraph (1), items (i) and (iii), paragraph (2), and paragraph (3) (Revocation of Tax Payment Grace Period) apply mutatis mutandis to the revocation of a disposition under the provisions of paragraph (2), paragraph (3), or the preceding paragraph. In this case, when the provisions of paragraph (1) of that Article are applied mutatis mutandis to the revocation of a disposition under the provisions of the preceding paragraph, the phrase "the district director, etc." in that paragraph is deemed to be replaced with "the competent collection agency, with the consent of the President of the National Tax Tribunal,".

The review officer (meaning a review officer prescribed in Article 11, paragraph (2) (Representatives) of the Administrative Complaint Review Act; the same applies in Article 108, paragraph (5) (Representatives)) for a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) may, if the review officer finds it necessary, submit to the Commissioner of the National Tax Agency a written opinion stating that the Commissioner should order the competent collection agency to grant a collection grace period or to suspend the continuation of the delinquent tax collection procedure under the provisions of paragraph (2), or to refrain from making an attachment or to release the attachment under the provisions of paragraph (3).

If an appellant dies, the heir (or, where the provisions of Article 951 (Formation of a Corporation of Inherited Property) of the Civil Code apply, the corporation referred to in that Article) succeeds to the status of the appellant.

If an appellant has undergone a merger or a split (limited to a split that causes the rights connected with the disposition that is the subject of the appeal to be succeeded to), the corporation surviving the merger or the corporation incorporated through the merger, or the corporation that has succeeded to those rights through the split, succeeds to the status of the appellant. The same applies to a corporation that has comprehensively succeeded to the rights and obligations belonging to the property of an association or foundation without legal personality that is an appellant.

In the cases referred to in the preceding two paragraphs, the person who has succeeded to the status of the appellant must notify the President of the National Tax Tribunal, etc. of that fact in writing. In this case, a document proving the fact of the succession to rights due to death or a split, or of the merger, must be attached to the written notification.

A person who has acquired by assignment the rights connected with the disposition that is the subject of an appeal may succeed to the status of the appellant with the permission of the President of the National Tax Tribunal, etc.

An appellant may appoint an attorney, a certified public tax accountant, or any other person the appellant finds appropriate as an agent.

Each agent referred to in the preceding paragraph may perform any and all acts concerning the appeal on behalf of the appellant; provided, however, that the withdrawal of the appeal and the appointment of an agent may be made only if the agent has been given a special mandate.

Necessary matters concerning the exercise of an agent's authority are specified by Cabinet Order.

If multiple persons jointly file an appeal, they may mutually elect not more than three representatives from among themselves.

If joint appellants do not mutually elect representatives, the President of the National Tax Tribunal, etc. may, if they find it necessary, order the mutual election of representatives.

Each representative may perform any and all acts concerning the appeal on behalf of the other joint appellants, excluding the withdrawal of the appeal.

When representatives have been appointed, the joint appellants may perform the acts referred to in the preceding paragraph only through the representatives.

A notice or other act of the President of the National Tax Tribunal, etc. (including the presiding tribunal judge and the review officer for a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) (Appeals against Dispositions concerning National Taxes)) directed to joint appellants suffices if made to one representative, even where two or more representatives have been appointed.

Joint appellants may dismiss representatives if they find it necessary.

Necessary matters concerning the exercise of a representative's authority are specified by Cabinet Order.

An interested person (meaning a person other than the appellant who is found to have an interest in the disposition to which the appeal pertains in light of the laws and regulations on which that disposition is based; the same applies in the following paragraph) may participate in the appeal with the permission of the President of the National Tax Tribunal, etc.

The President of the National Tax Tribunal, etc. may, if they find it necessary, request an interested person to participate in the appeal.

The provisions of Article 107 (Agents) apply mutatis mutandis to participation in an appeal by an intervenor (meaning a person who participates in the appeal pursuant to the provisions of the preceding two paragraphs).

An appellant may withdraw the appeal in writing at any time until a determination or decision on the appeal is made.

When a request for review has been made under the provisions of Article 75, paragraph (4) (Request for Review without a Determination on a Request for Reinvestigation), in the cases listed in the following items, the appeal specified in the respective item is deemed to have been withdrawn:

If a request for reinvestigation remains pending even after three months have elapsed from the day following the day on which it was made (or, if the requester was requested to correct a deficiency pursuant to the provisions of Article 81, paragraph (3) (Particulars to Be Stated in a Written Request for Reinvestigation, etc.), the day on which that deficiency was corrected), the reinvestigation authority must, without delay, instruct the requester for reinvestigation in writing that the requester may immediately make a request for review of the disposition to the President of the National Tax Tribunal.

The provisions of Article 89, paragraph (2) (Appending of Reasons for Dispositions) apply mutatis mutandis to the document for the instruction referred to in the preceding paragraph.

If an administrative organ that has made a disposition under a law concerning national taxes, in instructing on the administrative organ with which an appeal should be filed, has erroneously indicated an administrative organ that is not the proper one, and the appeal as instructed has been filed with the administrative organ so indicated, that administrative organ must promptly send the written request for reinvestigation or the written request for review to the administrative organ with which the request for reinvestigation should be made or to the President of the National Tax Tribunal or the Commissioner of the National Tax Agency, and notify the appellant to that effect.

If an administrative organ that has made a disposition under a law concerning national taxes (limited to a disposition against which a request for reinvestigation may be made; the same applies in the following paragraph) has erroneously failed to instruct that a request for reinvestigation may be made, and a request for review has been made to the President of the National Tax Tribunal and the requester for review has filed a petition, the President of the National Tax Tribunal must promptly send the written request for review to the administrative organ with which the request for reinvestigation should be made; provided, however, that this does not apply after the written answer has been sent to the requester for review pursuant to the provisions of Article 93, paragraph (3) (Submission of Written Answer, etc.).

If an administrative organ that has made a disposition under a law concerning national taxes has erroneously failed to instruct that a request for review may be made, and a request for reinvestigation has been made to a district director, regional commissioner, or director-general of customs and the requester for reinvestigation has filed a petition, that district director, regional commissioner, or director-general of customs must promptly send the written request for reinvestigation, etc. to the President of the National Tax Tribunal.

The administrative organ or the President of the National Tax Tribunal that has received the written request for review or the written request for reinvestigation, etc. pursuant to the provisions of the preceding two paragraphs must promptly notify the appellant and the intervenors to that effect.

When a written request for reinvestigation or a written request for review has been sent to the administrative organ with which the request for reinvestigation should be made or to the President of the National Tax Tribunal or the Commissioner of the National Tax Agency pursuant to the provisions of paragraphs (1) through (3), the request for reinvestigation is deemed to have been made to the administrative organ with which it should be made, or the request for review is deemed to have been made to the President of the National Tax Tribunal or the Commissioner of the National Tax Agency, from the beginning.

Part of the authority of the President of the National Tax Tribunal under this Act may be delegated to a chief National Tax Tribunal judge, pursuant to the provisions of Cabinet Order.

With regard to the application of the provisions of Article 19, paragraph (2) (Submission of Written Request for Review) of the Administrative Complaint Review Act in the case of making a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) (Appeals against Dispositions concerning National Taxes), the phrase "and domicile or residence" in item (i) of that paragraph is deemed to be replaced with ", domicile or residence, and identification number prescribed in Article 74-7-2, paragraph (3), item (iv), (c) of the Act on General Rules for National Taxes (Act No. 66 of 1962) (or, for a person who does not have an identification number, that person's name and domicile or residence)".

A request for review under the provisions of Article 75, paragraph (2) (limited to the part pertaining to item (ii)) may also be made via the district director who made the disposition to which the request for review pertains. In this case, the requester for review is to make it by submitting the written request for review to that district director.

In the case referred to in the preceding paragraph, the district director referred to in that paragraph must immediately send the written request for review to the Commissioner of the National Tax Agency.

In calculating the period for making a request for review in the case referred to in paragraph (2), the request for review is deemed to have been made at the time when the written request for review was submitted to the district director referred to in that paragraph.

When the Commissioner of the National Tax Agency has made a decision on a request for review under the provisions of Article 75, paragraph (2) (limited to the part pertaining to item (ii)), the Commissioner of the National Tax Agency must send a transcript of the written decision to the intervenors and the district director who made the disposition to which the request for review pertains, in addition to the requester for review.

Litigation concerning a disposition under a law concerning national taxes is governed by the Administrative Case Litigation Act (Act No. 139 of 1962) and other laws concerning general administrative case litigation, except as otherwise provided in this Section and in other laws concerning national taxes.

An action seeking the revocation of a disposition under a law concerning national taxes (excluding a disposition prescribed in Article 80, paragraph (3) (Relationship with the Administrative Complaint Review Act); the same applies hereinafter in this Section) against which an appeal may be filed may not be filed until after a decision on a request for review has been made; provided, however, that this does not apply if any of the following items applies:

A person who has made a determination or decision on a request for reinvestigation or a request for review filed against a disposition under a law concerning national taxes is to send, if litigation concerning that disposition is pending at the time when the determination or decision is made, a transcript of the written determination on reinvestigation or of the written decision to the court before which that litigation is pending.

In an action for the revocation of an original administrative disposition prescribed in Article 3, paragraph (2) (Action for the Revocation of an Original Administrative Disposition) of the Administrative Case Litigation Act that concerns a disposition under a law concerning national taxes (limited to a reassessment or determination, etc. and a notice of tax payment; referred to as a "tax assessment disposition" in this paragraph), if the person who has filed that action seeks to assert that the existence of the amount of necessary expenses or deductible expenses or any other similar fact favorable to that person differs from the facts on which the tax assessment disposition was based, that person must, without delay on or after the day on which the State, as the opposing party, has asserted the facts on which the tax assessment disposition was based, specifically assert that different fact and at the same time offer evidence to prove that fact; provided, however, that this does not apply if the person who has filed that action proves that, for reasons not attributable to that person, that person was unable to make the assertion or the offer of evidence without delay.

With regard to the application of the provisions of Article 157, paragraph (1) (Dismissal of Belated Means of Offense or Defense) of the Code of Civil Procedure (Act No. 109 of 1996), an assertion or offer of evidence made by the person who has filed the action referred to in the preceding paragraph in violation of the provisions of that paragraph is deemed to be a means of offense or defense submitted belatedly as prescribed in that paragraph.