Enforcement Rules of The Taxpayer Rights Protection Act Article 10

The term "the tax payable has not been determined over 15 years after the date on which the revoked or amended judgment is made by the court, may not be assessed again" in Paragraph 4 Article 21 of the Act refers to the commencement date being the date as follows:1.The date on which the court initially made the revocation or alteration of the judgement after the implementation of this law.2.When taxpayer appeals or protests against the final adjudication of the First Instance, the date on which the higher administrative court initially made the revocation or alteration of the judgment after the implementation of this law.The term“the date on which the court made the revocation or alteration of the verdict” depicted in the preceding paragraph means its announcement, or, if it is not announced, upon its publication.The term "not in this case" in the proviso of Paragraph 4 Article 21 of the Act refers to being assessed again even though the tax payable has not been determined over 15 years.
中文原文 納稅者權利保護法施行細則第10條
本法第二十一條第四項所定自法院作成撤銷或變更裁判之日起逾十五年未能確定其應納稅額者,不得再行核課,該十五年之起算日,依下列規定:
一、本法施行後法院最初作成撤銷或變更裁判之日。
二、納稅者對於第一審終局裁判提起上訴或抗告,於本法施行後經上級行政法院最初作成廢棄原裁判之日。
前項所稱作成撤銷、變更或廢棄原裁判之日,指宣示日;其不宣示者,為公告日。
本法第二十一條第四項但書所稱不在此限,指不受十五年不得再行核課期間之限制。

English translation for reference only; the Chinese text prevails. Not legal advice.