Article 47.

The duty-payer, who is dissatisfied with the determination referred to in the preceding Article, may file an appeal and then enter into administrative litigation according to the law.
In case any duty is refunded as a result of an irrevocable determination given on a review, appeal, or in administrative litigation, Customs shall refund it within ten days following the date of final determination. The refund shall include duty plus interest payable for the period beginning on the day following the date on which duty was paid by the duty-payer up to the date on which a refund notice or treasury check is issued, calculated on a daily basis according to the annual interest rate of one-year fixed savings in Postal Savings which is effective on the date on which the duty was paid.
In case any duty is recovered as a result of an irrevocable determination given on a review, appeal, or in administrative litigation, Customs shall issue a memo for the recoverable duty and notify the duty-payer to repay the duty, within ten days following the date of final determination. The duty to be recovered shall bear interest for the period beginning on the date following the prescribed tax or duty payment period up to the date on which the memo for the recoverable duty is issued, calculated on a daily basis according to the annual interest rate of one-year fixed savings in Postal Savings which is effective on the date on which the duty was paid.

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