The intention of the amendments is to make it so that it is clear that the GAAR conditions of the test would be satisfied where there have been tax attributes that have been created and could be used in the future even though they haven't been used yet. The department's intention is to ensure that, in the future, it's not open to taxpayers to argue that they haven't satisfied the GAAR because they haven't used the tax attributes.
On November 21st, 2022. See this statement in context.