①In the case where a person who falls under the provisions of Article 31, paragraph (2) has not filed an amended return under the provisions of that paragraph, the district director is to make a reassessment of that person's taxable value or amount of inheritance tax.

②In the case where any of the following items applies, the district director may make a reassessment or determination of the taxable value, the amount of inheritance tax, or the amount of gift tax, even before the deadline for filing a return:

③In the case where the district director has made a reassessment based on a request for reassessment under the provisions of Article 32, paragraph (1), items (i) through (vi), if any of the following grounds exists with respect to another person who has acquired property by inheritance or bequest from the decedent of the person who made the request (including a person who has acquired, by gift from that decedent, property to which the provisions of Article 21-9, paragraph (3) apply; the same applies hereinafter in this paragraph), the district director is to reassess or determine the taxable value or amount of inheritance tax of that person based on that ground; provided, however, that this does not apply on or after the later of the day on which one year has elapsed from the day of that request and the day on which reassessment or determination can no longer be made pursuant to the provisions of Article 70 (Time Limit for Reassessment and Determination, etc. of National Tax) of the Act on General Rules for National Taxes:

④In the case where, owing to the grounds listed below, the taxable value for inheritance tax or the amount of inheritance tax of a person who has filed a return referred to in item (i) or (iii), a person who has received a determination referred to in item (ii) or a reassessment referred to in item (iv) or (v), or another person who has acquired property by inheritance or bequest from the decedent of any of those persons (including a person who has acquired, by gift from that decedent, property to which the provisions of Article 21-9, paragraph (3) apply) has become excessive or deficient (excluding the case where the provisions of the preceding paragraph apply), the district director is to reassess or determine the taxable value for inheritance tax or the amount of inheritance tax of those persons; provided, however, that this does not apply on or after the later of the day on which one year has elapsed from the day on which the grounds listed below arose and the day on which reassessment or determination can no longer be made pursuant to the provisions of Article 70 of the Act on General Rules for National Taxes:

⑤The district director makes a reassessment or determination of the taxable value for gift tax or the amount of gift tax of a person who has been subject to the application of Article 21-2, paragraph (4), in the case where, because the person has come not to acquire property by inheritance or bequest owing to the occurrence of a cause prescribed in Article 32, paragraph (1), items (i) through (vi), the person has newly come to fall under the requirements for filing a return prescribed in Article 28, paragraph (1), or in the case where a shortfall has arisen in the amount of gift tax already finalized. However, this does not apply on or after the later of the day on which one year has passed from the day on which those causes arose and the day on which it becomes impossible to make a reassessment or determination under the provisions of Article 37.

In the case where, within six months before the day on which it becomes impossible to make a reassessment pursuant to the provisions of Article 70, paragraph (1) (Time Limit for Reassessment and Determination, etc. of National Tax) of the Act on General Rules for National Taxes, a request for reassessment has been made with respect to inheritance tax under the provisions of Article 23, paragraph (1) (Request for Reassessment) of that Act, and a change arises, in consequence of the reassessment relating to that request, in the taxable value for inheritance tax or the amount of inheritance tax of another person who has acquired property by inheritance or bequest from the decedent of the person who made that request (including a person who has acquired from that decedent by gift property subject to the application of Article 21-9, paragraph (3); the same applies hereinafter in this Article) (limited to the case where that request was made within six months before the day on which it becomes impossible, with respect to that other person and pursuant to the provisions of Article 70, paragraph (1) of that Act, to make the reassessment or determination, etc. prescribed in Article 58, paragraph (1), item (i), (a) (Interest on Refund) of that Act), a reassessment or determination relating to that inheritance tax, or an assessment and determination (meaning the assessment and determination prescribed in Article 32, paragraph (5) (Assessment and Determination) of that Act) made on the penalty tax prescribed in Article 69 (Tax Items for Penalty Tax) of that Act relating to that inheritance tax in conjunction with that reassessment or determination or the filing of a return filed after the deadline or an amended return, may be made until the day on which six months have passed from the day on which that request was made, notwithstanding the provisions of Article 70, paragraph (1) of that Act. In this case, with regard to the application of the provisions of Article 71, paragraph (1) (Special Provisions on Time Limits for Determination and Reassessment of National Tax) and Article 72 (Extinctive Prescription of the Right to Collection of National Tax) of that Act, the phrase "pursuant to the provisions of the preceding Article" in Article 71, paragraph (1) is deemed to be replaced with "pursuant to the provisions of the preceding Article and Article 36 of the Inheritance Tax Act (Special Provisions on Time Limits for Reassessment, Determination, etc. of Inheritance Tax)", the phrase "Notwithstanding the provisions of the preceding Article" with "Notwithstanding the provisions of the preceding Article and Article 36 of that Act", and the phrase "item (iv) of that paragraph was made" in Article 72, paragraph (1) with "item (iv) of that paragraph was made, and, in the case of inheritance tax to be paid by a reassessment or determination, etc. under the provisions of Article 36 of the Inheritance Tax Act (Special Provisions on Time Limits for Reassessment, Determination, etc. of Inheritance Tax) or the filing of a return filed after the deadline or an amended return under that Article, from the day on which that reassessment or determination, etc. or that filing was made".

①With respect to gift tax, notwithstanding the provisions of Article 70 (Time Limit for Reassessment and Determination, etc. of National Tax) of the Act on General Rules for National Taxes, the district director may make a reassessment or determination listed in the following items (hereinafter in this paragraph and paragraph (4) referred to as a "reassessment or determination") or an assessment and determination (meaning the assessment and determination prescribed in Article 32, paragraph (5) (Assessment and Determination) of that Act; the same applies hereinafter in this Article) until the day on which six years have passed from the deadline or day specified in each of those items. In this case, with regard to the application of the provisions of Article 71, paragraph (1) (Special Provisions on Time Limits for Determination and Reassessment of National Tax) of that Act, the phrase "pursuant to the provisions of the preceding Article" in that paragraph is deemed to be replaced with "pursuant to the provisions of the preceding Article and Article 37, paragraphs (1) through (4) of the Inheritance Tax Act (Special Provisions on Time Limits for Reassessment, Determination, etc. of Gift Tax)", and the phrase "Notwithstanding the provisions of the preceding Article" with "Notwithstanding the provisions of the preceding Article and Article 37, paragraphs (1) through (4) of that Act".

②A reassessment relating to a request for reassessment made under the provisions of Article 23, paragraph (1) (Request for Reassessment) of the Act on General Rules for National Taxes within six months before the day on which it becomes impossible to make a reassessment pursuant to the provisions of the preceding paragraph, or an assessment and determination made on penalty tax relating to gift tax in conjunction with that reassessment, may be made until the day on which six months have passed from the day on which that request for reassessment was made, notwithstanding the provisions of the preceding paragraph. In this case, with regard to the application of the provisions of Article 72, paragraph (1) (Extinctive Prescription of the Right to Collection of National Tax) of that Act, the phrase "Article 70, paragraph (3) (Time Limit for Reassessment and Determination, etc. of National Tax)" in that paragraph is deemed to be replaced with "Article 37, paragraph (2) of the Inheritance Tax Act (Special Provisions on Time Limits for Reassessment, Determination, etc. of Gift Tax)", and the phrase "prescribed in Article 70, paragraph (3)" with "prescribed in Article 37, paragraph (2) of that Act".

③An assessment and determination made, in conjunction with the filing of a tax return prescribed in Article 2, item (vi) (Definitions) of the Act on General Rules for National Taxes made within three months before the day on which it becomes impossible to make an assessment and determination pursuant to the provisions of paragraph (1), on penalty tax for failure to file relating to gift tax (limited to that to which Article 66, paragraph (8) (Penalty Tax for Failure to File) of that Act applies) may be made until the day on which three months have passed from the day on which that tax return was filed, notwithstanding the provisions of paragraph (1). In this case, with regard to the application of the provisions of Article 72, paragraph (1) of that Act, the phrases "paragraph (4) of that Article" and "Article 70, paragraph (4)" in that paragraph are deemed to be replaced with "Article 37, paragraph (3) of the Inheritance Tax Act (Special Provisions on Time Limits for Reassessment, Determination, etc. of Gift Tax)".

④A reassessment or determination, or an assessment and determination, on gift tax (including penalty tax relating to that gift tax) the whole or part of the amount of which has been evaded, or the whole or part of the amount of which has been refunded, by deception or other wrongful acts, and a reassessment of the amount of net loss, etc. prescribed in Article 2, item (vi), (c) of the Act on General Rules for National Taxes that arose in the taxable period prescribed in item (ix) of that Article and is stated in a tax return prescribed in item (vi) of that Article (where there was a reassessment regarding that amount, the amount after that reassessment), in the case where that tax return was filed on the basis that the amount of net loss, etc. was overstated by deception or other wrongful acts, may be made, notwithstanding the provisions of the preceding three paragraphs, until the day on which seven years have passed from the deadline or day specified in each of the following items according to the category of reassessment or determination or assessment and determination listed in the following items:

⑤In the case referred to in paragraph (1), the prescription of the national tax collection right prescribed in Article 72, paragraph (1) of the Act on General Rules for National Taxes relating to gift tax does not run for one year from the deadline for filing a return under the provisions of Article 28, paragraph (1) or (2) for that gift tax, except in the case where Article 73, paragraph (3) (Suspension of Completion and Renewal of Prescription) of that Act applies.

⑥In the case referred to in the preceding paragraph, the provisions of the proviso to Article 73, paragraph (3) of the Act on General Rules for National Taxes apply mutatis mutandis. In this case, the phrase "within two years" in the proviso to that paragraph is deemed to be replaced with "within one year".