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A consolidated fiscal group entity asks whether it can use an existing capitalisation reserve to meet the provisioning requirement and whether this constitutes an irrevocable tax option. The DGT confirms that using an existing reserve is possible and that the benefit is a right, not a tax option.
Entities in consolidated fiscal groups can utilise existing capitalisation reserves to meet provisioning requirements, and such arrangements are classified as rights rather than irrevocable tax options.
The tax team reviews your specific situation.
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