9. Amendment of section 46 of the principal enactment

Section 46 of the principal enactment is hereby amended in subsection (5) of that section by the repeal of paragraph (c) of that subsection and the substitution therefor, of the following paragraph: -

“(c)

at the time of the transfer-

prior to April 1, 2021-

the person and the associate were residents; and

the associate or, in the case of an associate partnership, none of its partners is exempt from income tax; and

on or after April 1, 2021-

the tax rate appliable on the person’s gain from the realisation of an asset referred to in subsection (4) is equal or less than the tax rate which is applicable on the gain of the associate from realisation of such asset; and”.