A tax shall be imposed on the shares of general partners in a partnership limited by shares, as in a partnership. Henceforth, the general partners' shares shall be deducted in determining the tax base of the partnership. The provisions of this Law which are applicable to partnerships shall apply to the shares of general partners in partnerships limited by shares.

In case of a change of 50% or more in the ownership or control of a capital company, no deduction is allowed for non-Saudi share of the losses incurred prior to the change according to Article 21 of this Law in the taxable years following the change, [unless the company continues to practice the same activity]^[21].

[The transfer of shares mentioned in paragraph (m) of Article 9 of these regulations is not considered a change in the ownership or control of the capital company.] ^[22].