Is SNS "Evidence" or "Simulation"? - Proposal for a "Substantial Merger Evaluation" Rule for SNS Evidence in Tax Investigations -
Global Union (National Tax Union) proposes the introduction of a "Substantial Merger Evaluation" rule for handling SNS information in tax investigations. This aims for a more rational and practical evidence evaluation by avoiding factual認定 based solely on SNS, integrating it with objective evidence, and confirming its context.
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- 📰 Published: April 30, 2026 at 00:12
- 🔍 Collected: April 29, 2026 at 15:31
- 🤖 AI Analyzed: April 29, 2026 at 17:38 (2h 7m after Collected)
■ Problem Statement — The Nature of SNS Information and Limits of Evidence Evaluation
With the advancement of digitalization, the instances where SNS interactions are referenced in tax investigations are increasing.
However, due to the inherent nature of SNS information, it is considered prudent to be cautious about immediately using only a snippet of a statement as grounds for factual認定.
SNS is a medium where the poster's intent, context, hypothetical expressions, and deliberation processes are intermingled, and understanding the entire context is indispensable for its interpretation.
■ The Position of SNS in Modern Management
In recent corporate activities, SNS is not merely used for external communication but can also be utilized for purposes such as:
・Material for virtual training (Scenario Planning, Adversarial Stress Testing)
・Records of crisis management simulations
・Deliberation process for narrative engineering
These are merely examples of general usage, and it goes without saying that judgment based on the actual circumstances of each individual case is necessary.
■ Structural Risk — How Misunderstandings Arise
Misunderstandings regarding SNS do not suddenly occur at a specific point in judgment, but rather are a structural problem that can arise through processes such as:
・Extracting only a part of a statement
・Lack of context
・Unconfirmed purpose
・Over-materialization of hypothetical expressions
This point is considered an important issue not only from the perspective of protecting taxpayers' rights but also from ensuring the appropriateness of administrative judgments.
■ Solution — "Substantial Merger Evaluation" Rule (Proposal)
This project proposes the introduction of the following evaluation method for handling SNS information:
1. Avoiding Factual认定 Based Solely on SNS
Making factual认定 based solely on SNS information may not be appropriate from the perspective of cautious evidence evaluation. Therefore, we propose an operation principle of comprehensive judgment in conjunction with other objective materials.
2. Integrated Evaluation with Objective Evidence
It is premised on confirming consistency with materials such as:
・Ledgers
・Contracts
・Transaction records
・Third-party testimonies, etc.
This categorizes SNS information as supplementary material.
3. Confirmation of Context and Purpose of Use
For SNS descriptions, it is desirable to go through a process of confirming:
・Background of the statement
・Antecedent and subsequent context
・Position in the deliberation process
Especially, if there is an aspect of hypothetical consideration or simulation, evaluation considering this point is required.
4. Balance of Assertion and Proof
If the taxpayer provides a reasonable explanation for the said description, a framework is needed to make a cautious judgment based on the overall evidence, taking into account that explanation.
This proposal does not change the legal allocation of the burden of proof but aims to ensure caution and rationality in evidence evaluation.
■ Institutional Significance — Ensuring Stability of Administrative Practice
This proposal, in addition to protecting taxpayers, is considered to contribute to the stability of administrative practice from the perspectives of:
・Ensuring rationality of judgment processes
・Improving objectivity of evidence evaluation
・Reducing dispute risks
Since disputes over the interpretation of SNS may arise in the future, organizing evaluation methods in advance is beneficial for both parties.
■ Position of This Proposal
This proposal:
・Does not negate the evidentiary value of SNS information
・Does not change existing legal interpretations
It merely presents a more rational and practical method for evidence evaluation within the current system, and we will continue to contribute to constructive discussions as a proposal to balance institutional stability and flexibility.
In the digital age, while the volume and speed of information have dramatically increased, the difficulty of its interpretation has also heightened.
Tax administration is also required to develop evaluation methods that take into account such environmental changes.
Global Union (National Tax Union) is promoting a solution development project that contributes to the sophistication of institutional operation and information management systems in national tax administration.
This project will be continuously promoted as an initiative aimed at national expansion, based on practical challenges identified in multiple regions and exchanges of opinions with national tax authorities.
Global Union (National Tax Union)
Web: https://globalunion-grp.org/mikata/u/kokuzeiunion/
Keywords:
With the advancement of digitalization, the instances where SNS interactions are referenced in tax investigations are increasing.
However, due to the inherent nature of SNS information, it is considered prudent to be cautious about immediately using only a snippet of a statement as grounds for factual認定.
SNS is a medium where the poster's intent, context, hypothetical expressions, and deliberation processes are intermingled, and understanding the entire context is indispensable for its interpretation.
■ The Position of SNS in Modern Management
In recent corporate activities, SNS is not merely used for external communication but can also be utilized for purposes such as:
・Material for virtual training (Scenario Planning, Adversarial Stress Testing)
・Records of crisis management simulations
・Deliberation process for narrative engineering
These are merely examples of general usage, and it goes without saying that judgment based on the actual circumstances of each individual case is necessary.
■ Structural Risk — How Misunderstandings Arise
Misunderstandings regarding SNS do not suddenly occur at a specific point in judgment, but rather are a structural problem that can arise through processes such as:
・Extracting only a part of a statement
・Lack of context
・Unconfirmed purpose
・Over-materialization of hypothetical expressions
This point is considered an important issue not only from the perspective of protecting taxpayers' rights but also from ensuring the appropriateness of administrative judgments.
■ Solution — "Substantial Merger Evaluation" Rule (Proposal)
This project proposes the introduction of the following evaluation method for handling SNS information:
1. Avoiding Factual认定 Based Solely on SNS
Making factual认定 based solely on SNS information may not be appropriate from the perspective of cautious evidence evaluation. Therefore, we propose an operation principle of comprehensive judgment in conjunction with other objective materials.
2. Integrated Evaluation with Objective Evidence
It is premised on confirming consistency with materials such as:
・Ledgers
・Contracts
・Transaction records
・Third-party testimonies, etc.
This categorizes SNS information as supplementary material.
3. Confirmation of Context and Purpose of Use
For SNS descriptions, it is desirable to go through a process of confirming:
・Background of the statement
・Antecedent and subsequent context
・Position in the deliberation process
Especially, if there is an aspect of hypothetical consideration or simulation, evaluation considering this point is required.
4. Balance of Assertion and Proof
If the taxpayer provides a reasonable explanation for the said description, a framework is needed to make a cautious judgment based on the overall evidence, taking into account that explanation.
This proposal does not change the legal allocation of the burden of proof but aims to ensure caution and rationality in evidence evaluation.
■ Institutional Significance — Ensuring Stability of Administrative Practice
This proposal, in addition to protecting taxpayers, is considered to contribute to the stability of administrative practice from the perspectives of:
・Ensuring rationality of judgment processes
・Improving objectivity of evidence evaluation
・Reducing dispute risks
Since disputes over the interpretation of SNS may arise in the future, organizing evaluation methods in advance is beneficial for both parties.
■ Position of This Proposal
This proposal:
・Does not negate the evidentiary value of SNS information
・Does not change existing legal interpretations
It merely presents a more rational and practical method for evidence evaluation within the current system, and we will continue to contribute to constructive discussions as a proposal to balance institutional stability and flexibility.
In the digital age, while the volume and speed of information have dramatically increased, the difficulty of its interpretation has also heightened.
Tax administration is also required to develop evaluation methods that take into account such environmental changes.
Global Union (National Tax Union) is promoting a solution development project that contributes to the sophistication of institutional operation and information management systems in national tax administration.
This project will be continuously promoted as an initiative aimed at national expansion, based on practical challenges identified in multiple regions and exchanges of opinions with national tax authorities.
Global Union (National Tax Union)
Web: https://globalunion-grp.org/mikata/u/kokuzeiunion/
Keywords: