Even if a Tax Prepayment (including a tax on delinquency levied against a Tax Prepayment) becomes subject to measures to collect arrears, the property of the taxpayer is not subject to a realization of assets under measures to collect arrears until that year's income tax Filing Deadline (or until the day on which any refund under Article 138, paragraph (1) (Refunding Tax Withheld) or Article 139, paragraph (1) or paragraph (2) (Refunding Prepaid Taxes) linked to the year's income taxes as of the deadline, is Appropriated to cover the arrears).