Article 147 sets strict statutes of limitation for issuing tax assessments. The standard limit is three years from the end of the tax year in which the return was submitted. However, this period is extended to five years if fraud or deception is involved. If a taxpayer fails to submit a return at all, the Authority has a five-year window from the original due date to issue an assessment. These limits provide taxpayers with eventual finality regarding their tax liabilities, while allowing the Authority sufficient time to conduct audits and uncover intentional evasion or non-filing.
Part 5 - Tax Assessment and Collection
Chapter 2 - Tax Assessment
Article 147
[GTL Notes: Assessment Time Limits]
No assessment may be made for any tax year after the expiry of three years from the end of the tax year during which the return of income for that tax year is submitted.
The time limit shall extend to (5) five years in cases of fraud or use of means of deception.
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