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V2178-19 ·14 August 2019 ·consulta-vinculante Medium impact
Tax

Limitation on offsetting tax loss carryforwards is governed by the regulations in force at the time of share acquisition

A company acquired before the entry into force of Law 27/2014 seeks clarification on whether the limitation on offsetting tax loss carryforwards under Article 26.4 of the Corporate Income Tax Act applies to it. The Directorate General of Taxes (DGT) rules that, since the acquisition occurred prior to the new law, the limitation applicable is that which was in force at the time of said acquisition.

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2019-08-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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