188. Period of limitations

Proceedings under this Chapter may be commenced where the offence alleged involves —

the doing of an act, within twelve years after the doing of the act;

the failure to do an act, within twelve years after the failure occurred or, if later, within three years after the Commissioner-General becomes aware of the failure; or

the non-disclosure or incorrect disclosure by a person of information relating to that person’s liability to pay tax, within three years after the person’s correct liability to tax becomes final for that tax period.