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7.1. General Rules

Losses can be carried forward indefinitely as adjusted by a cost-of-living increase. In case of change in ownership (i.e. change in 50% or more of the social rights in the entity), the carry forward of losses will be restricted for the year in which such ownership change occurs unless the relevant entity:

  • Has, at the time of the change, sufficient capital assets and resources to carry on its business; and
  • Continues to carry on its (original) main business activity at least during the 12 months following the change.

The carryback of losses is not permitted from 1 January 2017. Prior to that date, loss carryback was permitted  until the retained tax profits are absorbed.