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R105 – Carryover Rules by Country

Outlines how capital losses can be carried forward across tax years in supported countries.

Updated over 2 weeks ago

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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