Re-organizations

Income tax laws – Anti-avoidance provisions for re-organizations 

• A number of anti-avoidance provisions are introduced, which will give the right to the Tax Commissioner to refuse to accept tax free- reorganizations, if the Commissioner can determine that the main purpose or one of the main purposes of the reorganization is the reduction, avoidance or deferment of payment of taxes.
• The Commissioner will also have the right to impose conditions on the number of shares which can be issued as part of the re-organization and the period for which such shares should be held (not more than three years).

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