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).