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May 15, 2026

Article 15 limits the Authority's power to reassess previously determined tax years. Reassessment is only permitted if new information arises that significantly affects the taxpayer's obligations and was not considered during the initial assessment, all while adhering to the standard statute of limitations. The decision to reassess must follow the same procedural and notification rules as the original assessment. This provision provides taxpayers with a degree of finality and protection against arbitrary repeated audits, while allowing the Authority to correct assessments when fresh evidence of undeclared liabilities is discovered.

SECTION 5 - AUTHORITY POWERS AND DUTIES

Chapter 1 - Tax Assessment

Article 15

Subject to the statute of limitations provisions stipulated in this Law, the Authority may not reassess the tax due on the taxpayer for a tax year previously assessed unless new information affecting the taxpayer's tax obligations emerges that was not considered during the previous tax assessment.

The same rules applicable to the initial tax assessment apply to the decision to reassess the tax.