The provisions of Article 80, paragraph (1) of the New Corporation Tax Act (including as applied mutatis mutandis pursuant to paragraph (4) of that Article) apply to the net operating loss incurred in the business year that includes the day before the date of a company split by split-off or merger in the case where a corporation carries out, on or after the Effective Date, the company split by split-off or merger in which the corporation is the splitting corporation or acquired corporation, and with regard to the net operating loss incurred in the business year that includes the day before the date of a company split by split-off or merger in the case where a corporation carried out, before the Effective Date, the company split by split-off or merger in which the corporation was the splitting corporation or acquired corporation, the provisions then in force continue to govern.