Article 121 - Notice of Enquiry and Notice of Intention not to Enquire

(1) The Tax Department may enquire into a return filed under Article 109 if it gives notice of its intention to do so ("notice of enquiry") to the QFC Entity which filed the return, within the time allowed.
(2) The time allowed is—
(a) if the return was filed on or before the filing date, up to the end of the period of 12 months after the filing date;
(b) if the return was filed after the filing date, up to the end of the period of 12 months after the return was filed; and
(c) if the return is amended under Article 116, up to the end of the period of 12 months after the amendment was made.
(3) A return which has been the subject of one notice of enquiry may not be the subject of another, except one given in consequence of an amendment (or another amendment) of the return by the QFC Entity.
(4) The Tax Department may, with regard to any return or amended return, inform a QFC Entity by notice in writing that it does not intend to raise an enquiry under this Article in respect of that return or amended return.
(5) Where a notice has been given to a QFC Entity under Article 121(4) the Tax Department may not commence an enquiry under this Article into the return or amended return specified in the notice unless they form the opinion that the return or amended return was filed fraudulently or negligently.
Amended (as from 18th June 2014)