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The taxpayer asks whether negative tax bases can be offset following a change in shareholding resulting from an inheritance. The DGT determines that, since the requirement that new partners previously held less than 25% was not met, the limitation due to a change of control does not apply.
Question posed: Whether the accumulated negative tax bases can be offset from the 2018 fiscal year onwards, which is when the activity resumed (since the change in shareholding originated from a mortis causa transfer).
For the limitation on the offsetting of negative tax bases due to a change in shareholding to apply under the TRLIS, the new partner must have held a stake of less than 25% at the time the losses were generated. In this case, the spouse already held a 36% stake prior to the mortis causa transfer. Therefore, the negative tax bases may be offset against positive income subject to the limit set forth in Article 26.1 of the LIS.
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