In a national tax dispute, who may inspect the documents relating to their application, and where may an opinion be submitted?
General information · Not legal advice
Material to check
In practice material of this kind, we read the filing that shows which channel was used — an objection, a review request or a tax appeal — the list of papers each side filed in that channel, and any opinion statement sent to the agency that will rule.
These are types of material to look for, not evidence already verified by PRO SE.
Where readings differ
One reading takes the list of actors at face value: a person who has filed an objection, a review request or a tax appeal may inspect the documents relating to that application or request, and a disposition agency may do the same, but the disposition agency's right is limited to tax appeals, and an opinion may be submitted to the relevant ruling agency as the Presidential Decree prescribes.
Another reading stresses that the provision grants inspection of the documents relating to the application or request without defining how far that reaches into papers the ruling agency holds but no party filed, and it leaves open the manner of submitting an opinion, which the provision says the Presidential Decree prescribes.
Your judgment
Where the file shows a disposition agency that also filed the objection, how could the record show whether it acts in that dispute as applicant or as disposition agency?
PRO SE does not make this decision or keep a case record on this public site.When to reconsider
We look at this again if the provision is amended to change who may inspect documents or to which agency an opinion may be submitted, or if a Presidential Decree or court decision defines the documents relating to an application.