조세채권의 소멸시효의 중단：민법 제168조의 적용

[Purpose]This study conducts an in－depth examination of the interpretation of the grounds for the interruption of the statute of limitations on tax claims as stipulated in Article 28 of the National Tax Basic Act, with a particular focus on determining whether the interruption of the statute of limitations is recognised under Article 168 of the Civil Code through judicial claims. [Methodology]The study was conducted through literature review and legal interpretation, with a multifaceted analysis of the relationship between Article 28 of the National Tax Basic Act and Article 168 of the Civil Act. Key arguments include the principle of applying the more favourable provision, interpretation of the legislator’s intent, re－examination of the relationship between the deficiency disposition system and the statute of limitations system. [Findings]The study concluded that, in addition to the payment notice, demand, request for delivery, and attachment explicitly mentioned in Article 28 of the National Tax Basic Act, tax claims may also be subject to the interruption of the statute of limitations under Article 168 of the Civil Act, particularly through judicial claims. [Implications]This study broadens the legal interpretation of the grounds for the interruption of the statute of limitations on tax claims, enhances the stability of tax claim recovery, and contributes to strengthening the protection of tax claimants’ rights. It is anticipated that this study will lead to future court rulings explicitly recognising the interruption of the statute of limitations on tax claims through judicial claims.