General considerations
For tax periods beginning on or after January 1, 2015, taxpayers may offset negative tax bases with positive income from subsequent tax periods without any time limit (therefore, the maximum period of 18 years established by the previous regulations governing Corporate Tax is eliminated).
For these purposes, the twenty transitional provision of the establishes that negative tax bases pending compensation at the beginning of the first tax period that began on or after January 1 2015, may be compensated in the following tax periods.