No reassessment or determination, etc. listed in the following items may be made on or after the day on which five years (or three years, for an assessment and determination (excluding one that reduces the payable tax amount) pertaining to a national tax for which the filing of the tax basis return prescribed in item (ii) is required and for which that return has been filed) have elapsed from the due date or day specified in the relevant item:
reassessment or determination: the statutory tax return due date for the national tax to which the reassessment or determination pertains (for a reassessment pertaining to a return of refund claim, the day on which that return was filed, and for a determination under the provisions of Article 25 (Determination) to be carried out when no return of refund claim is filed, or a reassessment following such determination, the day specified by Cabinet Order);
an assessment and determination regarding the national tax for which a tax basis return is required to be filed:the due date of the filing of such return; or
an assessment and determination regarding the national tax subject to the official assessment system for which no tax basis return is required the day on which tax liability was established.
Notwithstanding the provisions of the preceding paragraph, a reassessment to increase or decrease the amount of net loss, etc. pertaining to corporation tax arising during the taxable period concerned, or a reassessment made on the assumption of the existence of that amount, may be carried out until the day on which 10 years have elapsed from the due date specified in item (i) of that paragraph.
Notwithstanding the provisions of the preceding two paragraphs, a reassessment pertaining to a request for reassessment made within six months before the day on which a reassessment can no longer be carried out pursuant to the provisions of the preceding two paragraphs, or an assessment and determination with regard to penalty tax to be imposed upon that reassessment, may be carried out until the day on which six months have elapsed from the day on which the request for reassessment was made.
Notwithstanding the provisions of paragraph (1), an assessment and determination with regard to penalty tax for failure to file (limited to that to which the provisions of Article 66, paragraph (8) (Penalty Tax for Failure to File) apply) or penalty tax for failure to pay (limited to that to which the provisions of Article 67, paragraph (2) (Penalty Tax for Failure to Pay) apply) to be imposed upon the filing of a tax return (including the payment of national withholding tax; the same applies hereinafter in this paragraph) made within three months before the day on which an assessment and determination can no longer be made pursuant to the provisions of paragraph (1) may be made until the day on which three months have elapsed from the day on which the tax return was filed.
Notwithstanding the provisions of paragraph (1) or the preceding two paragraphs, a reassessment or determination, etc. listed in the following items may be carried out until the day on which seven years have elapsed from the due date or day specified in the items of paragraph (1) for the types of reassessment or determination, etc. listed in those items:
a reassessment or determination, etc. of a national tax (including any penalty tax and negligence tax on the national tax) which a taxpayer evaded in whole or in part or of which the taxpayer received a partial or complete refund through deception or other wrongful acts;
a reassessment of the amount of net loss, etc. stated in a tax return which deceptively or otherwise wrongfully overstates the amount of net loss, etc. arising during the taxable period concerned (or if a reassessment of the amount has been carried out, the reassessed amount) (excluding a reassessment pertaining to the amount of net loss, etc. pertaining to corporation tax to which the provisions of paragraph (2) or paragraph (3) apply); and
a reassessment or determination, etc. of income tax (including any penalty tax on the income tax; referred to as "income tax subject to the special provisions for departure from Japan, etc." in Article 73, paragraph (3) (Suspension of Completion and Renewal of Prescription)) in the case where the provisions of Article 60-2, paragraphs (1) through (3) (Special Provisions on Capital Gains, etc. upon Departure from Japan) or Article 60-3, paragraphs (1) through (3) (Special Provisions on Capital Gains, etc. When Assets Are Transferred to a Nonresident through Gift, etc.) of the Income Tax Act apply (excluding the case where a notification of a tax agent has been made pursuant to the provisions of Article 117, paragraph (2) (Tax Agent) and a document has been submitted pursuant to the provisions of Article 30 (Clarification of Authority for Tax Representation) of the Certified Public Tax Accountant Act (Act No. 237 of 1951) (including as applied mutatis mutandis pursuant to Article 48-16 (Application Mutatis Mutandis of Provisions on the Rights, Obligations, etc. of Certified Public Tax Accountants) of that Act), and other cases specified by Cabinet Order).
所得税法第六十条の二第一項から第三項まで（国外転出をする場合の譲渡所得等の特例）又は第六十条の三第一項から第三項まで（贈与等により非居住者に資産が移転した場合の譲渡所得等の特例）の規定の適用がある場合（第百十七条第二項（納税管理人）の規定による納税管理人の届出及び税理士法（昭和二十六年法律第二百三十七号）第三十条（税務代理の権限の明示）（同法第四十八条の十六（税理士の権利及び義務等に関する規定の準用）において準用する場合を含む。）の規定による書面の提出がある場合その他の政令で定める場合を除く。）の所得税（当該所得税に係る加算税を含む。第七十三条第三項（時効の完成猶予及び更新）において「国外転出等特例の適用がある場合の所得税」という。）についての更正決定等