This Decision details conditions for Business Restructuring Relief under Article 27 of the Corporate Tax Law. This relief allows for the tax-neutral transfer of an entire business, or an independent part of it, in exchange for shares or other ownership interests. It specifies a limitation on non-share consideration, which cannot exceed the lower of the net book value of assets/liabilities transferred or 10% of the nominal value of ownership interests issued. Unutilised tax losses of the transferor may be carried over to the transferee. The relief is subject to clawback provisions if the shares or business are subsequently disposed of.