Loss set-off

(1) Negative income of the special investment fund is to be set off against positive income of the same type up to the amount of the latter. Sameness of type exists where the same tax effects occur for the investor.
(2) Negative income not set off is to be deducted in the following financial years. Section 10d(4) of the Income Tax Act applies accordingly. Negative income not set off is not deductible insofar as an investor disposes of its special investment units.