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Practical Manual for Companies 2021.

Limits of offsetting negative tax bases

Negative tax bases that have been subject to liquidation or self-assessment may be offset against positive income from tax periods with a limit of 70 percent of the base prior to the application of the capitalization reserve and its offset.

As established in the Fifteenth Additional Provision of the LIS , for taxpayers whose net turnover amount is at least 20 million euros during the 12 months prior to the date on which the tax period begins , the 70 percent limit will be replaced by the following:

  • 50 percent , when in the referred 12 months the net amount of the turnover is at least 20 million euros, but less than 60 million euros.

  • 25 percent , when in the referred 12 months the net amount of the turnover is at least 60 million euros.