(1)  If in the opinion of the Commissioner the actions of the taxpayer or the taxpayer's representative, or both the taxpayer and the taxpayer's representative, unnecessarily delay the making of a duty assessment, the Commissioner may impose interest from the end of the last day for payment until the day on which the duty is paid.

(2)  For the purposes of subsection (1) , the " last day for payment " is the last day of the period of 3 months after the liability for duty arises as provided in section 10 of the Duties Act 2001 .