(1) A taxpayer may make a request under section 106(1) for a review or appeal whether or not the tax to which it relates has been paid.
(2) If a taxpayer makes a request before the tax has been paid, the Commissioner may apply to the Supreme Court for an order that the tax, or a specified part of it, be paid before the review or appeal proceed.
(3) On an application under subsection (2), the Supreme Court may order that the review or appeal not proceed until the tax, or a specified part of it, is paid.
(4) The Supreme Court may make an order under subsection (3) only if satisfied that it is reasonably likely that, unless the order is made, any tax payable by the taxpayer in accordance with the determination of the review or appeal would not be paid within the period within which it is payable.