Statute of Limitation – Article 46 – Federal Tax Procedures Law

Article 46 – Statute of Limitation

1. Except in cases under Clauses 2, 3, 6 and 7 of this Article, the Authority may not conduct a Tax Audit or issue a Tax Assessment to a Taxable Person after the expiration of (5) five years from the end of the relevant Tax Period.

2. The Authority may conduct a Tax Audit or issue a Tax Assessment to the Taxable Person after (5) five years from the end of the relevant Tax Period, if he has been notified of the commencement of such Tax Audit’s procedures before the expiration of the (5) five-year period, provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within (4) four years from the date of Notification of the Tax Audit.

3. The Authority may conduct a Tax Audit or issue a Tax Assessment after the expiration of (5) five years from the end of the relevant Tax Period if such Tax Audit or Tax Assessment issuance relates to a Voluntary Disclosure submitted in the fifth year from the end of the Tax Period, provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within (1) one year from the date of submission of the Voluntary Disclosure.

4. The Cabinet may, according to a suggestion by the Minister, issue a decision to amend the period specified for the completion of the Tax Audit or the issuance of the Tax Assessment as per Clauses 2 or 3 of this Article.

5. No Voluntary Disclosure may be submitted after the expiration of (5) five years from the end of the relevant Tax Period.

6. In the case 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 in which the Tax Evasion occurred.

7. In case of Tax Registration failure, the Authority may conduct a Tax Audit or issue a Tax Assessment within (15) fifteen years from the date on which the Taxable Person should have registered for Tax.

8. The statute of limitation set forth in this Article shall be interrupted for any of the reasons provided for in the Federal Law 5 of 1985 promulgating the Civil Transactions Law, or any federal law replacing it.