The Tax Department has broad powers, including information powers, to enquire into returns. An enquiry must normally be opened within 12 months of a return being filed or amended as the case may be. This limited enquiry window, together with a provision allowing the Tax Department to indicate it does not intend to enquire into a return, gives QFC Entities a degree of certainty regarding their tax liability. The enquiry time limits are extended where the Tax Department considers there has been fraud or neglect. A QFC Entity may ask, by way of appeal, for an enquiry to be closed if it considers the Tax Department is not justified in continuing the enquiry.