Article 71Special Provisions on Time Limits for Determination and Reassessment of National Tax

一a reassessment or determination, etc. of national tax of a person who has received a National Tax Tribunal decision, a taxation agency determination or a judicial decision (hereinafter referred to as a "decision, etc." in this item) in an appeal against or action for a reassessment or determination, etc. of a national tax for which the tax basis, etc. or tax amount will change upon the change to the original disposition by such decision, etc. or upon the reassessment based on a request for reassessment (limited to national tax falling under the tax item which applies to the national tax to which the decision, etc. or reassessment pertains):six months from the day on which the decision, etc. or reassessment was made; or

二a reassessment to be carried out with regard to a national tax subject to the self-assessment system due to the fact that economic benefits arising from an invalid act included among the facts used as the basis for the calculation of the tax have been lost due to the invalidity of the act, or that an act that was voidable but included among these facts has been rescinded, or for other similar reasons specified by Cabinet Order (limited to a reassessment to decrease the payable tax amount, or a reassessment to increase the amount of net loss, etc. arising during the taxable period concerned or the amount of a refund, or a reassessment made on the assumption of the existence of these amounts), or an assessment and determination to be made with regard to a penalty tax on such national tax upon such reassessment: three years from the day on which the event constituting the reason occurred;

四a reassessment or determination, etc. carried out based on the event listed in (b) where the event listed in (a) has occurred: three years from the day on which the document pertaining to the request referred to in (b) was sent to the treaty partner under the tax treaty, etc. referred to in (b).

イthe fact that, where the relevant official of the National Tax Agency, a Regional Taxation Bureau or a tax office has requested a taxpayer to present or submit documents (including, where an electronic or magnetic record has been prepared or retained in lieu of the preparation or retention of the documents, that electronic or magnetic record) or copies thereof relating to overseas transactions (meaning sales of assets, purchases of assets, provision of services or other transactions conducted with a nonresident (meaning a nonresident as prescribed in Article 2, paragraph (1), item (v) (Definitions) of the Income Tax Act; the same applies in (a)) or a foreign corporation (meaning a foreign corporation as prescribed in Article 2, item (iv) (Definitions) of the Corporation Tax Act; the same applies in (a)), or sales of assets, purchases of assets, provision of services or other transactions conducted by using a venue provided by a nonresident or a foreign corporation) or overseas assets (meaning the property prescribed in Article 20-2 (Deduction of the Amount of Inheritance Tax for Overseas Property) of the Inheritance Tax Act) pertaining to the national tax, the documents or copies were not presented or submitted by the day designated by the relevant official within a period not exceeding 60 days from the day on which the presentation or submission was requested, by taking into consideration the number of days normally required for their preparation (excluding the case where there are no grounds attributable to the taxpayer);

ロthe fact that, where the Commissioner of the National Tax Agency (including a person delegated by the Commissioner) has, pursuant to the provisions of a tax treaty, etc., requested the treaty partner under that tax treaty, etc. to provide information on the overseas transactions or overseas assets referred to in (a) (excluding the case where the request was made on or after the day six months before the day on which a reassessment or determination, etc. can no longer be carried out pursuant to the provisions of the preceding Article, and limited to the case where the taxpayer referred to in (a) was notified that the request had been made within three months from the day on which the request was made), an error is found with regard to the tax basis, etc. or tax amount, etc. of the national tax in light of the information provided by the treaty partner.