Tax Collection Act Article 21

Assessment period shall be determined in accordance with the following provisions:1.For the tax which should be declared and paid by a taxpayer under the law and has been declared within the statutory period when filing a tax return, and which the taxpayer has no intention to evade by fraud or any other unrighteous means, the assessment period shall be five (5) years.2.For the stamp tax payable by a taxpayer under the law and any other tax which should be assessed by the tax authorities based on the data recorded in the Tax Registration Book or obtained through investigation, the assessment period shall be five (5) years.3.For the tax which is not declared within the statutory period when filing tax returns or has been intentionally evaded by the taxpayer by fraud or any other unrighteous means, the assessment period shall be seven (7) years.During the assessment period set forth in the preceding Paragraph, if any additional tax is found to be assessable on the same taxpayer under investigation, the taxpayer shall still be so assessed and required to make payment thereof and/or subject to punishment; however, no additional tax may be assessed and punishment imposed in respect of any additional tax which is found to be assessable after the expiry of the applicable statutory assessment period.At the expiry of the assessment period, in one of the following circumstances, an assessment can still be made:1.In a case where a taxpayer is dissatisfied with the tax assessment and seeks administrative remedy, or if the tax assessment is cancelled by an administrative appeal or the court, the assessment period shall be 1 year from the date of cancellation.2.If the tax assessment cannot be determined within the assessment period due to the occurrence of natural disasters or Uincident or a case of force majeure, the assessment period shall be six months from the date of the disappearance of the cause.Where the tax assessment is subject to re-check at the request of the taxpayer after expiry of the assessment period or is cancelled by an administrative appeal or the court within a year prior to the expiry of the assessment period, Subparagraph 1 of the preceding paragraph shall apply mutatis mutandis.The assessment period does not apply to the provisions of Paragraph 3 of Article 131 through Article 134 of the Administrative Procedure Act regarding the interruption of the statute of limitations.In the cases not currently being assessed or pending final decision on the effective date of the amendment of this Act on November 30, 2021, Paragraphs 3 to 5 shall apply.