Taxation Administration Act 2001

A reassessment increasing a taxpayer’s liability for tax must be made in the limitation period.

Despite subsection (1), a reassessment increasing a taxpayer’s liability for tax may be made at any time—

if the commissioner reasonably believes there has been a deliberate tax default; or

if, within the limitation period, the commissioner has given written notice to the taxpayer informing the taxpayer an investigation into the taxpayer’s liability for tax has started under either or both of the following—

part 7;

a recognised law.

For subsection (2)(a), a deliberate tax default arises if—

there has been fraud or evasion of tax; or

a taxpayer or person acting for a taxpayer knowingly misleads the commissioner, or causes the commissioner to be misled, about the taxpayer’s liability for tax, including, for example, by giving, omitting or changing information or documents.