S.L. 123.205 Art. 3Surrender of allowable deductions.

Allowable deductions may be surrendered by a company, hereinafter referred to as "the surrendering company", and, on the making of a claim by another company, hereinafter referred to as "the claimant company", be allowed to the claimant company as a deduction against its total income:

Provided that the total allowable deductions that may be claimed shall not exceed one million euro (€1,000,000) per group of companies and the total amounts surrendered in each year of assessment shall be equal to the amounts so claimed in each year of assessment:

Provided further that the total allowable deductions that may be claimed by a claimant company in the year of assessment 2022 and in the year of assessment 2023 shall not exceed the claimant company’s total income for the years of assessment 2022 and 2023 respectively:

Provided further that the surrendering of allowable deductions shall only be allowed if either the surrendering company or the claimant company is a beneficiary.