Article 46 - Reorganisations and Reconstructions Carried out for Bona Fide Commercial Reasons
(1) If a QFC Entity carries out a reorganisation or reconstruction not covered by Articles 42 to 45—
(a) for bona fide commercial reasons; and
(b) if obtaining a tax advantage was not the main object, or one of the main objects, of the transaction or series of transactions, the Tax Department shall, on application by the QFC Entity , consider treating the transaction or series of transactions constituting the reorganisation or reconstruction in a tax neutral manner.
(2) The Tax Rules may contain provisions regarding the form and manner in which an application under Article 46(1) is to be made (TAX 14).