Loss Carry Forwards

In principle, losses from seven business years preceding the tax period (Art. 79) may be deducted from net profits for the tax period to the extent that the losses could not be taken into account in calculating taxable net profits for these years (Art. 67 Para 1 FITA).

This principle does not hold in the course of an Asset Deal. In this case, the buyer may not carry over and forward the losses incurred by the buyer.