The time limitation for the utilization tax losses carried forward from previous periods have changed multiple times, having raised several questions in taxpayers.
According to previous rules, tax losses realized between 2004 and 2014 could be utilized for an unlimited time. As of 1 January 2015, the tax loss carry forward rules had changed and as a result, tax losses realized after 1 January 2015 can be utilized up to five years following the realization of the respective tax loss for corporate income tax purposes.
Besides the amended regulation, a grandfathering rule sets forth that unused tax losses incurred in the tax year commencing in 2014 or before can be used up until the tax year containing 31 December 2025 regardless of the above detailed limitations.
A lately submitted modification indicated that, the deadline of using up the tax losses incurred in 2014 or before to the tax year containing the date 31 December 2030. This extension can be considered as especially beneficial for taxpayers who incurred tax losses in said period, but may not have been able to fully utilize such losses within the currently effective time frame up to 2025.
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