51% of a mixed company is owned by Saudis, while the rest 49% is owned by a foreign partner with accumulated losses. If the Saudi partners sell their shares to another partner, does the foreign partner lose his right to deduct the accumulated losses due to the sale of his share in the company?

As stipulated in Article 11 paragraph (4) of the Implementing Regulations, losses of a company in which a change or modification of its ownership or control is 50% or more are not permitted to be carried forward except for losses that occur after the change in ownership (Unless the company continues to conduct the same business activity).

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51% of a mixed company is owned by Saudis, while the rest 49% is owned by a foreign partner with accumulated losses. If the Saudi partners sell their shares to another partner, does the foreign partner lose his right to deduct the accumulated losses due to the sale of his share in the company?