Carry forward and set off of losses restricted by majority shareholding continuity; special start up and limited exceptions apply. Section 79 restricts carry forward and set off of losses after a change in shareholding: non public companies (other than eligible start ups) may not carry forward prior losses unless persons who held a majority of voting power when the loss arose continue to hold a majority on the last day of the previous year. Eligible start ups may carry forward losses if all shareholders who held voting shares when the loss arose continue to hold those shares and the loss arose within seven years of incorporation. Exceptions cover transfers on death or gift to a relative and specified foreign amalgamation/demerger cases.