Can I contest customs additional taxation prior notice through pre-taxation review?

Hello. This is the tax-specialized attorney from Daeryun Law Firm (LLC).

Pre-taxation review is a procedure prepared so that taxpayers' opinions can be reflected before customs revises and notifies tariffs.

According to the Customs Act, when the customs head intends to additionally collect tariffs, in principle, the content must be notified in writing in advance, and taxpayers who receive this notice can request pre-taxation review.

The request period is within 30 days from the date of receiving the pre-taxation notice, and in principle, the request is made to the head office customs head, but depending on the case, direct request to the Commissioner of the Korea Customs Service is also possible.

In this procedure, you can appoint an attorney or licensed customs broker as your agent for professional response.

When pre-taxation review is requested, the customs head suspends revision and notification until a decision is made, and decisions are usually made within 30 days through deliberation by the Customs Review Committee.

However, the customs imposition exclusion period cannot be exceeded.

The decision results have the same binding force as subsequent objections or review requests, and separate appeals against the decision itself are not allowed.

Therefore, pre-taxation review is most importantly a response that sufficiently organizes the facts and legal principles in the early stage, and it is desirable to strategically use it through review by a tax-specialized attorney.