소득금액변동통지에 대한 고찰

In the course of adjusting the difference between the enterprise accounting and the tax accounting, we judged whether the amount in adjustment matters is reserved within the company or if not so whether it is flowed out of the company, and then performed the disposition of income which clearly decides the belongings of that amount. At this times, it is general which the income tax is additionally imposed through the withholding way as well as the corporation tax is levied upon the part which belongs to the Individual after being out of the company and also as its precedent procedures, the form of “Notification of the change on Income” is indicated outward and then its contents make notified to the withholding obligator. In case the Tax Withholding Liability happens upon the Notification of the change on Income, we express sympathy with which we must have the opportunity to present any objection upon it, before it is reached to the disposition of Withholding Notification for the purpose of protecting the right & power of withholding obligator, but there is the opposing view on its concrete ways. Recently, the Supreme Court acknowledges its disposition on the “Notification of the change on Income” and so makes the appeal to be filed, and thus the censure is concluded, but there is still the juridical problems. Then, the Notification of the change on Income is not only the simple action of notification and causes the complicated legal problems in the harmony interpretation with the regulation of other tax law, giving the effect of presume for payable period and payment. So, we would like to examine the meaning, legal matter, procedures & cancellation and repeal of Notification on the change on Income, relationship with the procedures succeeding after its disposition is acknowledged, and other problems related, on the assumption of its disposition, and moreover to note its corrected points as the conclusion.