Year of convergence means the tax year or previous year in which the convergence date falls, depending on applicable law.

The year of convergence is defined by reference to the period in which the convergence date falls. For the purposes of the relevant subsection, section 206 of the Income Tax Act, 2025, identifies it as the tax year containing that date. Section 115JB of the Income Tax Act, 1961, instead identifies it as the previous year containing the convergence date.

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