Comparative analysis of the anti-loss trafficking rules in Germany, Australia and the United States

The approaches taken by Germany, Australia and the United States to prevent "loss trafficking in companies", which occurs when a profitable company acquires an unprofitable company with accumulated tax losses only for the purpose of carrying over the losses and setting them off against the profits of the profitable company, are examined. Comparative analysis of the anti-loss trafficking rules and summary of the differences between the restrictions on loss carry-overs in these three countries.