By means of recent amendments to the Income Tax Act, implemented through the Budget Measures Implementation Act XII of 2023 published on the 4th April 2023, Article 27A has been amended so that the transfers that qualify for special treatment due to restructuring will also include transfers between companies and persons that are related to such companies, provided they meet the conditions that are specified in the rules. New rules are intended to be published by the Commissioner to implement these measures.
This measure comes into force on the 4th April 2023 i.e. date of publication.