一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);

二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

三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.

一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;

二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

三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).

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;

三a reassessment pertaining to a request for reassessment in the case where the provisions of Article 10, paragraph (2) (Special Provisions for Computation of Periods and Due Dates) or Article 11 (Extension of Due Dates due to Disasters, etc.) apply to the due date by which the request for reassessment may be made, or an assessment and determination with regard to penalty tax to be imposed upon that reassessment: six months from the day on which the request for reassessment was made; or

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.