The realization of an asset by way of merger, amalgamation, or reorganization under section 47 of the Income Tax Act, 2015 (Act 896) has specific tax treatment. The gains on the realization of an asset in such cases are exempt from tax if the following condition is met:

• There must be continuity of at least 50% ownership of the underlying asset by the shareholders or owners.
  If this condition is met, the gains derived from the merger, amalgamation, or reorganization are not subject to capital gains tax.