(1) Interest accrues on a tax default that occurs before, but continues after, the date of transition as if this Act had been in force when the relevant tax liability was incurred.
(2) Penalty tax may be imposed under this Act for a tax default occurring before the date of transition.
(3) The powers conferred by this Act to remit interest or penalty tax extend to interest that accrued before the date of transition and to any penalty or additional tax payable under the old law.