[Tichy]

Won't this just lead to businesses changing their organizational structure, then carrying on as before? For example, instead of creating departments in a big company, one could split it into several smaller companies. (I don't really know the tax law in question, but it sounds like a potential loophole).

[graphene]

I wouldn't think so, because this applies only to capital gains tax, i.e. only becomes relevant when the company is sold. I don't think there would be any advantage in transforming departments into separate companies, and then cayying on as before..