Since the introduction of the tax consolidation regime entities that have not elected to be part of a 'tax consolidated group' will not be able to transfer tax losses to other entities:

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Under the tax consolidation regime, tax losses can only be transferred within the tax consolidated group. Entities that have not elected to be part of a tax consolidated group are not able to transfer their tax losses to other entities.

Since the Introduction of the Tax Consolidation Regime Entities That