BUSINESS MERGERS AND ACQUISITIONS ACT Article 48

Any loss from the transaction in which a company applied its business or assets in subscribing or exchange for the shares from another company and the value of such acquired shares is lower than the book value of the business or assets may be amortized within fifteen years; provided, however, that any loss incurred, that is prevented from deduction from the income pursuant to Article 44, may not be amortized.