Period of limitations

Proceedings under this Part may be commenced if the offence alleged involves the– (a) doing of an act, within twelve years after the doing of the act; (b) failure to do an act, within twelve years after the failure occurred or, if later, within three years after the Director General becomes aware of the failure; or (c) non-disclosure or incorrect disclosure by a person of information relating to that person’s liability under a tax law, within three years after the person’s correct liability to tax becomes final for that tax period.