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.

However, with effect for tax periods starting on or after 1 January 2024 and not ending on 22 December 2024, section 1 of the Fifteenth Additional Provision of the LIS establishes that 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.