Article 61 sets out transitional rules for implementing Corporate Tax. It specifies a Taxable Person’s opening balance sheet for tax purposes shall be the closing balance sheet from the financial year preceding their first Tax Period. This opening balance sheet must be prepared in accordance with accounting standards applied in the State and consider the arm's length principle. Critically, it gives early effect to the general anti-abuse rule (GAAR) in Article 50, making it applicable to transactions entered into from the date the Decree-Law was published in the Official Gazette.