1. Except for the cases set out in Clauses (2), (3), (4), (7), and (8) hereunder, the Authority may not conduct a Tax Audit or issue a Tax Assessment on the Taxable Person after (5) five years from the end of the relevant Tax Period. 2. The Authority may conduct a Tax Audit or issue a Tax Assessment on the Taxable Person after (5) five years from the end of the relevant Tax Period if the Taxable Person is notified of the commencement of such Tax Audit prior to the lapse of that five-year period; provided that the Tax Audit or the Tax Assessment, as the case may be, is completed within four (4) years from the date of the Tax Audit Notification. 3. The Authority may conduct a Tax Audit or issue a Tax Assessment after (5) five years from the end of the relevant Tax Period if such Tax Audit or Tax Assessment is related to a Voluntary Disclosure that had been submitted during the fifth year following the end of the Tax Period; provided that the Tax Audit or the Tax Assessment, as the case may be, is completed within one (1) year from the date of submitting the Voluntary Disclosure. 4. The Authority may conduct a Tax Audit or issue a Tax Assessment after (5) five years from the end of the relevant Tax Period if such Tax Audit or Tax Assessment is relate to a refund of Tax or credit balance application submitted during the fifth year following the end of the Tax Period referred to in Clause (2) of Article (38) of this Decree by Law, or during the periods referred to in Clauses (3) and (4) of Article (38) hereof, as applicable, provided that the Tax Audit or the Tax Assessment, as the case may be, is completed within (2) two years from the date of submitting the refund application. 5. The Cabinet, upon the proposal of the Minister, may issue a resolution amending the timeframe prescribed for the completion of the Tax Audit or the issuance of the Tax Assessment, pursuant to Clauses (2), (3) or (4) of this Article. 6 Voluntary Disclosure shall be submitted following the lapse of (5) five years from the end of the relevant Tax Period, except for a Voluntary Disclosure submitted in accordance with Clause (2) of Article (10) of this Decree by Law where it relates to a refund application for which the Authority has not yet issued a decision. 7. In cases of Tax Evasion, the Authority may conduct a Tax Audit or issue a Tax Assessment within (15) fifteen years from the end of the Tax Period during which the Tax Evasion occurred. 8. In cases of non-registration for tax, the Authority may conduct a Tax Audit or issue a Tax Assessment within fifteen (15) years from the date on which the Taxable Person was required to register for Tax. 9. The statute of limitations set forth in this Article shall be interrupted for any of the reasons set forth in Federal Law No. (5) of 1985 Enacting the Law of Civil Transactions or any superseding federal law.
Interpretation and application must be checked against the official text and current version.