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A company enquired whether it should apply the reduction to the tax loss carryforwards of an absorbed company under Article 84.2 of the CIT Act. The DGT ruled that the limitation does not apply if there is no double compensation of losses at both the shareholder and the absorbing company levels.
Cuestión planteada 1. Si resulta de aplicación la limitación a la compensación de las bases imponibles negativas regulada en el artículo 84.2 de la Ley 27/2014, de 27 de noviembre, del Impuesto sobre Sociedades.
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