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A consulting company asks how much of the negative tax bases of the absorbed company can be offset following a merger. The DGT responds that those losses corresponding to the tax impairment that the absorbed company was required to recognize between 2008 and 2013 may not be offset.
Question posed: It is asked whether this conclusion is correct and, failing that, to determine the amount of negative tax bases generated by the absorbed company that may be deductible by the absorbing company.
The negative tax bases of the transferring entity may not be offset by the acquiring entity in the amount of the tax impairment that the transferring entity was required to recognize in the periods beginning between January 1, 2008, and January 1, 2013. This is because, pursuant to the forty-first transitional provision of the TRLIS, negative bases that motivated the depreciation of the holding in periods prior to 2013 are not offsettable. The tax expense for impairment should have been imputed in the period in which the decrease in equity occurred through an extra-accounting adjustment.
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