Country | Carryover Rules | Notes |
United States (IRS) | Unlimited carryover until losses are used | Up to $3,000 ($1,500 if married filing separately) deductible per year against ordinary income |
United Kingdom (HMRC) | Unlimited carryover | Losses must be claimed on your tax return; not automatic |
Canada (CRA) | Unlimited carryover | Must be applied on your return; can offset future capital gains |
Germany | Unlimited carryover | Cannot offset ordinary income; applies only to future gains |
Spain | 4-year carryover limit | Losses must be used within 4 years |
Italy | 5-year carryover limit | After 5 years, unused losses expire |
Ireland | Unlimited carryover | Offsets only capital gains |
India | 8-year carryover limit | Losses must be declared in a timely filed return |
Japan | 3-year carryover limit | Primarily for securities/stock transactions |
South Africa | Unlimited carryover | Restricted to future capital gains only |
Australia (ATO) | Unlimited carryover | Cannot offset ordinary income |
New Zealand | Unlimited carryover | Valid as long as returns are filed on time |
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