<![CDATA[The elimination of Article 13 paragraph (5) of Law Number 6 of 1983 concerning General Provisions and Tax Procedures as last amended by Law Number 7 of 2021 concerning Harmonization of Tax Regulations creates ambiguity regarding the expiration date of the Initial Evidence Examination (Bukper) in the enforcement of criminal tax law. This condition causes an unclear relationship between the expiration date of tax administration and the expiration date of criminal prosecution, thus potentially reducing legal certainty and protection of taxpayer rights. This study aims to analyze the legal regulations and ambiguity of the Bukper expiration date and reconstruct the ideal regulations to ensure legal certainty and protection of taxpayer rights. The research method used is normative legal research with a statutory approach, a conceptual approach, and a case approach, using primary, secondary, and tertiary legal materials analyzed prescriptively. The results of the study indicate that the Bukper regulations still contain legal gaps, unclear norms, and norm conflicts due to the absence of explicit regulations regarding the Bukper expiration date. Regulatory reconstruction needs to be implemented through amendments to the General Taxation Law (KUP) by regulating the legal status of Bukper (Persero), the deadline for audit initiation, the timeframe for completion, and the protection of taxpayers' procedural rights to ensure legal certainty, legal protection, and effective enforcement of criminal tax law.]]>
