Legal analysis: the five-year tax penalty period is due to the responsibility of the tax authorities, resulting in taxpayers and withholding agents not paying or underpaying taxes.

The decision on tax administrative punishment shall specify the following items:

1. Name and address of the party concerned;

2. Facts and evidence in violation of laws, regulations or rules;

3, the types and basis of administrative punishment;

4, the way and time limit of administrative punishment;

5, refuses to accept the decision on administrative punishment, the way and time limit for applying for administrative reconsideration or bringing an administrative lawsuit;

6. The name of the tax authority that made the punishment decision and the date of making the decision.

Legal basis: Article 11 of the Administrative Punishment Law of the People's Republic of China. If no illegal acts are found within two years, no administrative punishment will be given. Except as otherwise provided by law. The time limit prescribed in the preceding paragraph shall be counted from the date when the illegal act occurs. If the behavior is in a continuous or continuous state, it shall be counted from the date when the behavior ends.