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A query was raised regarding whether an entity can offset its negative tax bases if its employees acquire its share capital. The DGT ruled that, under certain hypotheses, such offsetting is possible, but warns that a subsequent change of control could prevent it.
Question raised 1. For the purposes of applying paragraph 4 of Article 26 of the Corporate Income Tax Law, if the employees acquire shares in the entity, could they offset future positive taxable bases with the negative bases presented.
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