(1) Where the Comptroller has taken all steps permissible under this Act to recover tax and the Comptroller is unable to recover any amount of tax, penalty and interest due and payable under this Act by a person for a specified period, the Comptroller shall advise the Minister and the Minister may remit the matter to the Comptroller for the steps to be re-taken or may, subject to reinstatement under subsection (3), order the extinguishment of the liability as a debt due to the Crown.
(2) An Order made under subsection (1) shall be approved by Cabinet.
(3) If the Comptroller determines that a person subject to an order under subsection (1) has assets that may be attached to recover the unpaid tax, penalty and interest specified in the order, then with the approval of Cabinet, the order may be revoked and the liability reinstated.