①When the presiding tribunal judge finds that the necessary examination has been completed, the presiding tribunal judge is to conclude the review proceedings.

②Beyond what is provided for in the preceding paragraph, the presiding tribunal judge may conclude the review proceedings if any of the following items applies:

③When 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.

①If 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.

②If a request for review is groundless, the President of the National Tax Tribunal rejects the request for review by a decision.

③If 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.

④When 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.

①When 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.

②In 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.

③If 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.

①A 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:

②The provisions of Article 84, paragraph (8) (Procedures for Determinations, etc.) apply mutatis mutandis to the decision referred to in the preceding paragraph.

③A 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).

④The 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).

①A decision binds the relevant administrative agencies.

②If 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.

③If 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.

④If 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 articles of 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).

①The 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.

②If 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.

③In 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.

④The 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.

①An 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.

②The 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.

③If 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.

④The 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 a customs house 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.

⑤If 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.

⑥When 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.

⑦The 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,".

⑧The 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).