164. Lien

Where a taxpayer fails to pay a tax by the due date, a lien in favour of the Commissioner-General shall be created in the amount owing (together with interest, penalty and costs of collection that may accrue) on all property belonging to the taxpayer, and has priority as against all other rights, except as otherwise provided in this section.

The lien referred to in subsection (1) shall arise at midnight at the commencement of the date of default and shall continue until the liability is satisfied or becomes unenforceable by reason of lapse of time.

The lien imposed under this section shall not be valid against the interest of a person who is a purchaser from the taxpayer, a holder of a security interest granted by the taxpayer, or other lien holder specified in regulations, if the interest arises—

The Commissioner-General may file notice of a lien at any time after a taxpayer is determined to be in default pursuant to section 152.

The Commissioner-General may specify procedures for filing notice of a lien and may specify categories of interests against which the lien shall not be valid even though notice of the lien has been filed.

At least fifteen days prior to registering a lien with the

Subsection (6) shall not apply where the

The Commissioner-General may file action in the High

An affected person may apply to the Commissioner-General for a release of the lien on the person’s property and a decision by the Commissioner-General not to release a lien may be appealed to the High Court.