40It is apparent from the request for a preliminary ruling that, following the judgment of 12 February 2009, Cobelfret (Case C‑138/07, EU:C:2009:82), the DTI system was altered. In accordance with Article 205(3) of the ITC 1992, the part of the DTI that cannot be deducted in the relevant tax year due to insufficient profits may now be carried forward to subsequent tax years. In addition, the ability to carry forward is not limited in time. It is therefore apparent that the reduction in losses which may be carried forward, due to the inclusion of dividends in the parent company’s tax base, is now offset by an unlimited ability to carry forward DTI in the same amount.
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