국세불복제도 운용현황 분석 및 개선방안

[Purpose]This study examines the current status of the tax appeal system, examines problems and improvement measures, and suggests implications for the tax appeal system to perform its effective rights protection function. [Methodology]This paper analyze national tax appeal data collected from the National Tax Service(NTS), the Board of Audit and Inspection(BAI), and the Tax Tribunal(TT) from 2008 to 2023. [Findings]First, the number of request for pre－assessment review, the request for reconsideration and the request for review by the NTS decreased, but the number of the appeal to the TT increased significantly. Next, the average appeal acceptance rate over the entire period followed this order：request for pre－assessment review, appeal to the TT, request for review by the NTS, request for reconsideration and request of examination by the BAI. Lastly, we report that there is a statistically significant difference in the appeal acceptance rate by type of tax and size of tax amount requested. In the overall administrative procedure, the appeal acceptance rate for corporate tax and inheritance tax was higher than that for other taxes, and in tax litigation, the appeal acceptance rate for corporate tax and gift tax was higher than that for other taxes. A higher appeal acceptance rate was reported in sections with larger tax amount requested than in sections with smaller tax amount requested. This was more evident in the appeal to the TT and in tax litigation. [Implications]This study is expected to contribute to enhancing the taxpayer rights protection function of the tax appeal system by analyzing the current state of tax appeal system and examining related problems and improvement measures.