Foreign losses incurred by permanent establishments of resident companies may be offset against domestic profits unless the losses are incurred by an exempt foreign permanent establishment. Foreign losses realized by a permanent establishment located in an EU Member State may be set off against domestic income if they are no longer deductible in the country of the permanent establishment.
Tax Research & Compliance
The world’s most complete array of cross-border tax analysis and data
The world’s most complete array of cross-border tax analysis and data