Any taxpayer who fails to pay the tax due within thirty (30) days after the expiration of the statutory period for payment of such tax shall be referred to compulsory execution by the tax authorities, unless said taxpayer has filed an application for recheck pursuant to the provisions set out in Article 35 hereof.
Unless under any of the following circumstances, a case requiring compulsory execution of payment of tax due and being held in abeyance pursuant to the preceding Paragraph shall be referred to compulsory execution by the tax authorities:
1.Where the taxpayer has paid one third (1/3) of the amount of tax payable determined in a recheck decision and filed an administrative appeal in due course; or
2.Where the taxpayer has difficulties in paying one third (1/3) of the amount of tax payable as prescribed under the preceding Subparagraph and has furnished an equivalent collateral as security upon the approval of the tax authorities; or
3.Where the taxpayer has difficulties in paying one third (1/3) of the amount of tax payable and has furnished an equivalent collateral as security as prescribed under the preceding two Subparagraphs, and, according to Subparagraph 1, Paragraph 1 of Article 24, the tax authorities have notified the government authorities concerned to prohibit said taxpayer from transferring or creating other rights over the property of the taxpayer at a value equivalent to the amount of tax payable determined in a recheck decision the outstanding tax payable.
In cases where there were tax payable determined in a recheck decision, prior to the entry into force of the amendment to this Article on November 30, 2021, and the taxpayer has not paid one-half (1/2) of the amount of tax payable or has not furnished an equivalent collateral as security as prescribed under the preceding Paragraph, and the tax authorities have not yet referred to compulsory execution, the provisions after the amendment shall apply.For cases that have been transferred to administrative law enforcement agencies for enforcement before the revision on November 30, 2021 or whose enforcement has been suspended in accordance with the provisions of Paragraph 2, the provisions before the revision shall apply.

In the event that the tax authorities deem it improper to have referred a taxpayer to compulsory execution of the payment of tax due, it may withdraw such case. If the compulsory execution is in process, the tax authorities shall apply for cessation of the compulsory execution in process.