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July 11, 2026
This anti-avoidance rule prevents 'tax loss trafficking'. Carried-forward losses are disallowed if there is a change of more than 50% in the company's ownership. For the loss to be utilised, the same person(s) must have continuously owned at least 50% of the entity from when the loss arose until it is used. An exception exists if, despite an ownership change exceeding 50%, the Taxable Person continues to conduct the same or a similar business. The rule does not apply to companies whose shares are listed on a Recognised Stock Exchange.
Chapter 11 - Tax Loss Provisions
Article 39 - Limitation on Tax Losses Carried Forward
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