-   restriction on the carry-forward of losses to address situations of change in ownership prior to the deduction of the losses; -   foreign tax credit is limited to the lower of the foreign income tax actually paid, or the Portuguese tax that is proportionally attributable to the foreign-source income, after the deduction of all expenses and losses directly or indirectly incurred in obtaining such income (for companies), or after the deduction of allowances in conformity with the individual income tax (for individuals); -   carry-forward of any excess foreign tax credit is no longer available; Dividend stripping The...