Framework Act on National Taxes — Deadlines, Service of Documents and Succession to Tax Liability
Articles are cited from the version in force on 11 August 2026 (Act No. 21860), checked on 20 September 2026.
What the previous seven chapters did not say
We have counted countless periods: exclusion periods of 5, 7 and 10 years, five years for requests for correction, 90 days for appeals, 30 days for pre-assessment review. All were counted “from the day notice was received” or “from the day one learned of the disposition”.
But when is notice received? What if registered mail comes back? What if the address is unknown? What if the last day falls on a Sunday?
The answers are in the general provisions of Chapter 1 of the Act. We return to them last because every period calculation so far rests on these articles. We also look at who takes over the liability when a taxpayer dies or corporations merge.
Special rules on deadlines (Article 5)
When a deadline for a return, application, request, submission of documents, notice, payment or collection falls on one of the following, the next day is the deadline:
- Saturday or Sunday;
- public holidays and substitute holidays under the Act on Public Holidays;
- Labour Day under the Act on the Designation of Labour Day.
Item 3 is easy to miss. Workers’ Day is not a statutory public holiday, but this article includes it separately. The wording was tidied up by the amendment of 11 November 2025.
Paragraph 3 is also practical. If on the last day for filing or payment the national tax information network is shut down by a failure specified by presidential decree so that electronic filing or payment is impossible, the deadline becomes the day after the day the failure is fixed and filing or payment becomes possible.
Postal and electronic filing (Article 5-2)
For electronic filing, the deadline for submitting certain related documents specified by presidential decree may be extended by up to 10 days (paragraph 3).
Extension of deadlines for disasters etc. (Article 6)
The head of the competent tax office may extend a deadline when it is recognised that it cannot be met because of a natural disaster or a reason specified by presidential decree, or when the taxpayer applies.
This article appeared twice in earlier chapters: the grounds for not imposing penalty tax in chapter 4 (Article 48(1)1) include “a ground for extending a deadline under Article 6”, and the 14-day special rule for requests for review in chapter 5 (Article 61(4)) refers to “a reason under Article 6”.
Service of documents — to whom (Article 8)
The rule is the addressee’s domicile, residence, place of business or office. For electronic service, it is the addressee’s email address (or, if stored on the national tax information network, a place accessible with the user’s identification code).
| Paragraph | Situation | Served on |
|---|---|---|
| 2 | Joint taxpayers | The representative; if none, the person most favourable for collection. But payment notices and demands go to each of them |
| 3 | An inheritance has commenced and there is an administrator of the estate | The administrator's address or place of business |
| 4 | There is a tax administrator | Payment notices and demands to the tax administrator's address or place of business |
| 5 | The addressee is confirmed to be arrested, detained or held in a correctional facility or police lock-up | The head of that facility or police station |
The proviso to paragraph 2 matters. Ordinary documents may go to one representative, but payment notices and demands must be sent separately to every joint taxpayer. A demand to pay must reach each person directly.
If the addressee reports a place for service, documents must be served there, including after any change (Article 9).
Methods of service (Article 10)
There are three: delivery, post and electronic service (paragraph 1).
The registered-mail rule (paragraph 2)
Documents relating to payment notices, demands, enforced collection or government orders under the tax laws must be sent by registered mail when posted.
The only exceptions allowing ordinary mail are four kinds of payment notices for amounts below a threshold set by presidential decree: notices of interim prepayment of income tax, notices under Article 48(3) of the Value-Added Tax Act, notices issued because tax reported on a return was not paid (taxes under Article 22(2)), and notices issued because tax shown on a withholding status report was not paid.
The common thread is visible: the taxpayer already knows the tax exists. Since no new burden is being announced, the need for proof of delivery is weaker.
When the addressee cannot be found (paragraphs 3 and 4)
Service by delivery is made by an official handing the documents over in person at the place of service, but they may be handed over elsewhere if the addressee does not refuse.
If the addressee is not found at the place of service, documents may be served on an employee, worker or cohabitant capable of understanding the matter (substituted service). And if the addressee or any of them refuses without good reason, the documents may be left at the place of service (service by deposit).
If the addressee has moved, the new address must be confirmed from the resident register or similar and service made there (paragraph 5). Sending to the old address is not enough.
On delivery, the recipient’s signature or seal is obtained on the service record, and any refusal is noted (paragraph 6). For ordinary mail, a record of the document’s title, name, place, date of dispatch and main content must be kept (paragraph 7).
Electronic service (paragraphs 8 to 10)
It is used only on application. But if the taxpayer voluntarily pays before a payment notice is served, an application for electronic service is deemed made at that point.
If documents served electronically go unopened three times in a row, the application is deemed withdrawn (paragraph 9), unless the tax on electronically served notices and demands was paid in full by the deadline. If you paid without opening them, you are treated as having received them.
If the national tax information network fails, documents may be served by delivery or post (paragraph 10).
Service by public notice (Article 11)
In three cases, documents are deemed served 14 days after the main content is publicly announced:
- the domicile or place of business is abroad and service is difficult;
- the domicile or place of business is unclear;
- cases specified by presidential decree where none of the persons in Article 10(4) (the addressee, employees, workers or cohabitants) is at the place of service, such as when registered mail is returned because the recipient is absent.
Public notice is made in one of the following: the national tax information network, the tax office notice board, the website or notice board of the competent city, county or district, or the Official Gazette or a daily newspaper. However, the national tax information network must be used together with another method (paragraph 2). Online alone is not enough.
Effect of service — the arrival principle (Article 12)
Documents served take effect when they reach the person to be served.
Electronic service is deemed to arrive when entered at the designated email address (or, if stored on the national tax information network, when stored).
It is the time of arrival, not dispatch. The taxpayer does not bear the risk of postal delays. Article 17 of the National Tax Collection Act (extension of the designated payment deadline for late service — 14 days from arrival) is an extension of the same principle.
Succession to tax liability
Merger (Article 23)
The surviving or newly established corporation after a merger is liable for national taxes and enforced collection costs imposed on, or payable by, the dissolved corporation.
There is no limit, because a merger transfers all rights and obligations universally.
Inheritance (Article 24)
Heirs, or an administrator of the estate under Article 1053 of the Civil Act, are liable for the decedent’s national taxes and enforced collection costs up to the value of the property received by inheritance.
Unlike a merger, there is a limit. Heirs are not liable beyond what they inherited — the same structure as the limits on secondary tax liability in chapter 3.
If there are two or more heirs, each pays jointly, up to the value of property received by inheritance, the amount divided according to the statutory inheritance shares under the Civil Act. They must also appoint a representative and report to the head of the competent tax office (paragraph 3).
Joint tax liability (Article 25)
| Paragraph | Situation | Limit |
|---|---|---|
| 1 | National taxes and collection costs relating to co-owned property, a joint business or property belonging to it — co-owners and joint business operators | None |
| 2 | After a split-off where the splitting corporation survives — the splitting corporation, the new corporation and the counterparty in a split-merger | Value of property succeeded to in the split |
| 3 | After a split or split-merger where the splitting corporation ceases to exist — the new corporation and the counterparty in a split-merger | Value of property succeeded to in the split |
| 4 | A new company is established under Article 215 of the Debtor Rehabilitation and Bankruptcy Act — the new company | None |
Only paragraph 1 has no limit; the two split-related paragraphs are limited to the value of property succeeded to. Co-ownership and joint businesses are one’s own business, whereas a split means receiving a share of someone else’s obligations.
The provisions on joint obligations from Article 413 of the Civil Act apply mutatis mutandis to joint tax liability (Article 25-2).
Eight chapters on one page
This course never calculates a single tax. Income tax, corporate tax and VAT do not appear. The Framework Act is a frame laid over all taxes in common. Whatever tax you study, it moves within this frame.
What remains
- Organisations deemed corporations (Article 13) and some of the principles of assessment and application (Articles 14–20) were covered in chapter 1.
- Extinction of tax liability (Article 26) was covered together with exclusion periods and prescription in chapter 2.
- Chapter 8 of the Act (supplementary provisions: tax administrators in Article 82, rewards in Article 84-2, compliance charges in Article 85-7) and Chapter 9 (penalties) are not covered.
References
- Korea Law Information Center, Framework Act on National Taxes, Articles 5, 5-2, 6, 8, 9, 10, 11, 12, 23, 24, 25 and 25-2 (in force 11 August 2026, Act No. 21860; checked 2026-09-20)
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