The law as Cabinet Order Partially Amending the Order for Enforcement of the Consumption Tax Act (Cabinet Order No. 96 of 2026) leaves it, with the words it changes marked.
The main text is read a page at a time: a chapter to a page, and a long chapter in runs of articles. The whole main text, and the supplementary provisions and appended tables this amendment changes. Those it leaves untouched are on the page for the text in force.
Article 28第二十八条
Special Provisions on Trustees of Trusts Subject to Corporate Taxation, etc.（法人課税信託等の受託者に関する特例）
Article 28, paragraph (1)（法人課税信託等の受託者に関する特例）Special Provisions on Trustees of Trusts Subject to Corporate Taxation, etc.Changed
In the application of the provisions of Article 32, paragraph (7), Article 33, paragraph (1), Article 34, paragraph (1), Article 35, Article 35-2, paragraphs (1) and (2), Article 36, paragraph (3), Article 38, paragraph (4), Article 38-2, paragraph (4) and, Article 39, paragraph (6) and Article 40, paragraph (5) of the Act and the provisions of Article 38, paragraph (2) and Article 41 to a trustee business operator (meaning a trustee business operator prescribed in Article 15, paragraph (3) of the Act; the same applies hereinafter in this Article), a merger of trusts is deemed to be a merger, a trustee business operator relating to a trust subject to corporate taxation, etc. (meaning a trust subject to corporate taxation, etc. prescribed in Article 15, paragraph (1) of the Act; the same applies hereinafter in this Article) that is a former trust relating to a merger of trusts is deemed to be included in a merged corporation, a trustee business operator relating to a trust subject to corporate taxation, etc. that is a new trust relating to a merger of trusts is deemed to be included in a merging corporation, a trust split is deemed to be a company split, a trustee business operator relating to a trust subject to corporate taxation, etc. that transfers part of its trust property by a trust split as the trust property of another trust with the same trustee or of a new trust is deemed to be included in a splitting corporation, and a trustee business operator relating to a trust subject to corporate taxation, etc. that receives a transfer of part of the trust property from another trust with the same trustee by a trust split is deemed to be included in a successor corporation in a company split.
In the application of Article 15, paragraph (6) of the Act in the case where the taxable period that includes the first day prescribed in Article 15, paragraph (6) of the Act of an own-assets business operator (meaning an own-assets business operator prescribed in Article 15, paragraph (4) of the Act; the same applies hereinafter in this Article) (hereinafter in this paragraph referred to as the "own-assets taxable period") is any of the taxable periods set out in the items of Article 20, or in the case where the own-assets business operator has been subject to the application of Article 20-2, paragraph (1) or (2) with respect to the own-assets taxable period, the following apply:
In the case where the own-assets taxable period is any of the taxable periods set out in the items of Article 20, and the own-assets business operator has submitted, during that own-assets taxable period, the written notification under Article 9, paragraph (4) of the Act in order to be subject to the application of that paragraph for that own-assets taxable period (where the taxable period of the trustee business operator referred to in Article 15, paragraph (6) of the Act that includes the first day prescribed in Article 15, paragraph (6) of the Act ends before the last day of that own-assets taxable period, limited to the case where it has been submitted by the last day of that taxable period), or in the case where the own-assets taxable period is the taxable period for which the own-assets business operator intends to be subject to the application of Article 9, paragraph (4) of the Act, and that own-assets business operator has received approval under Article 20-2, paragraph (1) with respect to that own-assets taxable period because of the unavoidable circumstances prescribed in Article 20-2, paragraph (1), those own-assets business operators are deemed, on the first day prescribed in Article 15, paragraph (6) of the Act, to have been business operators for which the obligation to pay consumption tax is not exempted by the submission of a written notification under Article 9, paragraph (4) of the Act.
In the case where the own-assets taxable period is the taxable period for which the own-assets business operator intends to cease to be subject to the application of Article 9, paragraph (4) of the Act, and that own-assets business operator has received approval under Article 20-2, paragraph (2) with respect to that own-assets taxable period because of the unavoidable circumstances prescribed in Article 20-2, paragraph (2), that own-assets business operator is deemed, on the first day prescribed in Article 15, paragraph (6) of the Act, not to have been a business operator for which the obligation to pay consumption tax is not exempted by the submission of a written notification under Article 9, paragraph (4) of the Act.
The amount calculated as specified by Cabinet Order prescribed in Article 15, paragraph (7) of the Act relating to a trustee business operator is to be, according to the category of amounts set out in the following items, the amount specified in the relevant item:
the taxable sales in the specified period relating to the business year of a trustee business operator (meaning the taxable sales in the specified period prescribed in Article 9-2, paragraph (1) of the Act; the same applies hereinafter in this item): the amount calculated under paragraph (2), item (i) of the preceding Article (including where it is applied with the terms replaced pursuant to paragraph (3), item (ii) of that Article) as the taxable sales in the specified period of the own-assets business year, etc. prescribed in paragraph (2), item (i) of the preceding Article that includes the first day of that business year of that trustee business operator, being an own-assets business year, etc. of the own-assets business operator of the trust subject to corporate taxation, etc. relating to that trustee business operator;
the taxable sales for the taxable period of a trustee business operator (meaning the taxable sales for the taxable period prescribed in Article 30, paragraph (2) of the Act; the same applies hereinafter in this item): the amount calculated under paragraph (2), item (iii) of the preceding Article (including where it is applied with the terms replaced pursuant to paragraph (3), item (iii) of that Article) as the taxable sales for the taxable period preceding the taxable period of an own-assets business operator, being the own-assets business operator of the trust subject to corporate taxation, etc. relating to that trustee business operator, that includes the last day of that taxable period of that trustee business operator (where the last day of the taxable period of that trustee business operator and the last day of the taxable period of that own-assets business operator are the same day, the taxable sales of that own-assets business operator for that taxable period).
In the application of Article 15, paragraph (8) of the Act in the case where the taxable period that includes the first day prescribed in Article 15, paragraph (8) of the Act of an own-assets business operator (hereinafter in this paragraph referred to as the "own-assets taxable period") is any of the taxable periods set out in the items of Article 56, paragraph (1), or in the case where the own-assets business operator has been subject to the application of Article 57-2, paragraph (1) or (2) with respect to the own-assets taxable period, the following apply:
In the case where the own-assets taxable period is any of the taxable periods set out in the items of Article 56, paragraph (1), and the own-assets business operator has submitted, during that own-assets taxable period, the written notification under Article 37, paragraph (1) of the Act in order to be subject to the application of that paragraph for that own-assets taxable period (where the taxable period of the trustee business operator referred to in Article 15, paragraph (8) of the Act that includes the first day prescribed in Article 15, paragraph (8) of the Act ends before the last day of that own-assets taxable period, limited to the case where it has been submitted by the last day of that taxable period), or in the case where the own-assets taxable period is the taxable period for which the own-assets business operator intends to be subject to the application of Article 37, paragraph (1) of the Act, and that own-assets business operator has received approval under Article 57-2, paragraph (1) with respect to that own-assets taxable period because of the unavoidable circumstances prescribed in Article 57-2, paragraph (1), those own-assets business operators are deemed, on the first day prescribed in Article 15, paragraph (8) of the Act, to have been business operators subject to the application of Article 37, paragraph (1) of the Act.
In the case where the own-assets taxable period is the taxable period for which the own-assets business operator intends to cease to be subject to the application of Article 37, paragraph (1) of the Act, and that own-assets business operator has received approval under Article 57-2, paragraph (2) with respect to that own-assets taxable period because of the unavoidable circumstances prescribed in Article 57-2, paragraph (2), that own-assets business operator is deemed, on the first day prescribed in Article 15, paragraph (8) of the Act, not to have been a business operator subject to the application of Article 37, paragraph (1) of the Act.
Where a former trust relating to a merger of trusts or a split trust relating to a trust split (meaning a trust that transfers part of its trust property to another trust or a new trust by a trust split; the same applies in the following paragraph) is a trust subject to corporate taxation (meaning a trust subject to corporate taxation prescribed in the proviso to Article 14, paragraph (1) of the Act; the same applies hereinafter in this Article) (limited to a trust set out in Article 2, item (xxix)-2, (a) or (c) (Definitions) of the Corporation Tax Act; hereinafter in this paragraph referred to as a "specified trust subject to corporate taxation"), the new trust relating to that merger of trusts, or the other trust or the new trust relating to that trust split (excluding a specified trust subject to corporate taxation), is deemed to be a specified trust subject to corporate taxation.
Where a merger of trusts or a trust split (limited to one in which a single trust transfers part of its trust property to a new trust; hereinafter in this paragraph and the following paragraph referred to as a "single split into a new trust") is carried out, in the case where that merger of trusts makes a trust subject to corporate taxation the new trust, the former trust relating to that merger of trusts (excluding a trust subject to corporate taxation) is deemed to have become a trust subject to corporate taxation immediately before that merger of trusts, and in the case where that single split into a new trust makes a group investment trust (meaning a group investment trust prescribed in Article 2, item (xxix) of the Corporation Tax Act; the same applies hereinafter in this paragraph) or a trust taxed on its beneficiaries (meaning a trust in which the beneficiary prescribed in Article 14, paragraph (1) of the Act (including a person deemed to be a beneficiary prescribed in Article 14, paragraph (1) of the Act pursuant to Article 14, paragraph (2) of the Act) is deemed to hold the assets belonging to its trust property; the same applies hereinafter in this paragraph and paragraph (8)) the split trust and makes a trust subject to corporate taxation the successor trust (meaning a trust that receives, by a trust split, a transfer of part of the trust property of a split trust from that split trust; the same applies hereinafter in this paragraph and the following paragraph), that successor trust is deemed to have become a trust subject to corporate taxation from a group investment trust or a trust taxed on its beneficiaries immediately after that single split into a new trust.
Where a trust split under which part of the trust property is transferred to another trust (hereinafter in this paragraph and the following paragraph referred to as an "absorption-type trust split") or a trust split under which two or more trusts transfer part of their trust property to a new trust (hereinafter in this paragraph and the following paragraph referred to as a "new trust split by multiple trusts") has been carried out, the provisions of the preceding two paragraphs apply on the deemed basis that a single split into a new trust with the trust whose trust property is the trust property transferred by that absorption-type trust split or new trust split by multiple trusts (hereinafter in this paragraph referred to as an "interim trust in an absorption-type split") as the successor trust has been carried out, and that a merger of trusts with that interim trust in an absorption-type split and the successor trust (in the case of a new trust split by multiple trusts, the other interim trusts in an absorption-type split) as the former trusts has been carried out immediately thereafter.
Where a former trust pertaining to a merger of trusts prescribed in paragraph (6) (including, where the provisions of the preceding paragraph apply, a trust that transfers part of its trust property by an absorption-type trust split or a new trust split by multiple trusts) is a trust taxed on its beneficiaries, if there is anything that is deemed to be a contribution prescribed in Article 2, paragraph (1), item (iii) (limited to a taxable transfer, etc. of assets), then, notwithstanding paragraph (6), that which is deemed to be that contribution is deemed to have been made to the new trust pertaining to the merger of trusts prescribed in that paragraph (where the provisions of the preceding paragraph apply, the other trust referred to in the preceding paragraph pertaining to the absorption-type trust split or the new trust referred to in the preceding paragraph pertaining to the new trust split by multiple trusts).
Where a trustee business operator pertaining to a trust subject to corporate taxation (limited to a trust listed in Article 2, item (xxix)-2, (d) or (e) of the Corporation Tax Act; the same applies in the following paragraph) is subject to the application of Article 14-6, paragraph (8) of the Order for the Enforcement of the Corporation Tax Act with respect to its accounting period (meaning the accounting period prescribed in Article 14-6, paragraph (8) (Trust Subject to Corporate Taxation) of the Order for the Enforcement of the Corporation Tax Act; the same applies in paragraphs (11) and (12)), the provisions of the Act and this Cabinet Order apply to that trustee business operator as a corporation whose business year is one year.
With regard to the application of the provisions of the Act and this Cabinet Order concerning the number of months in the business year of a trustee business operator pertaining to a trust subject to corporate taxation that falls under the case prescribed in the preceding paragraph (referred to as a "specified trustee business operator" in the following paragraph), the number of months in that business year is 12 months.
When applying paragraphs (1) and (2) of the preceding Article (including where these provisions are applied with terms replaced pursuant to paragraph (3) of the preceding Article), Article 22 as applied with terms replaced pursuant to paragraph (4) of the preceding Article, Article 23 as applied with terms replaced pursuant to paragraph (5) of the preceding Article, Article 25-4 as applied with terms replaced pursuant to paragraph (6) of the preceding Article, and Article 25-5, paragraph (4) as applied with terms replaced pursuant to paragraph (7) of the preceding Article, if the trustee business operator prescribed in those provisions is a specified trustee business operator, those provisions are applied on the basis that the business year of that specified trustee business operator ends on the day on which one year elapses from the first day of its accounting period.
Where a trustee business operator of a trust subject to corporate taxation is subject to the application of Article 14-6, paragraph (10) or (11) of the Order for the Enforcement of the Corporation Tax Act with respect to its accounting period, the provisions of the Act and this Cabinet Order are applied by deeming the period deemed to be a business year under those provisions to be a business year of that trustee business operator.
Where the own-assets business operator of a trust subject to corporate taxation, etc. is a qualified invoice issuer, the provisions of the Act and this Cabinet Order are applied to the trustee business operator of that trust subject to corporate taxation, etc. by deeming it to have received the registration under Article 57-2, paragraph (1) of the Act. In this case, the phrase "registration number (" in Article 57-4, paragraph (1), item (i) of the Act is deemed to be replaced with "registration number of the own-assets business operator (meaning the own-assets business operator prescribed in Article 15, paragraph (4); the same applies in item (i) of the following paragraph and paragraph (3), item (i)) of the trust subject to corporate taxation, etc. (meaning the trust subject to corporate taxation, etc. prescribed in Article 15, paragraph (1); the same applies in item (i) of the following paragraph and paragraph (3), item (i)) pertaining to the trustee business operator (meaning the trustee business operator prescribed in Article 15, paragraph (3); the same applies in item (i) of the following paragraph and paragraph (3), item (i)) (", the phrase "registration number" in Article 57-4, paragraph (2), item (i) and paragraph (3), item (i) of the Act is deemed to be replaced with "registration number of the own-assets business operator of the trust subject to corporate taxation, etc. pertaining to the trustee business operator", and the phrase "registration number (" in Article 49, paragraph (4), item (ii) is deemed to be replaced with "registration number of the own-assets business operator prescribed in Article 15, paragraph (4) of the Act of the trust subject to corporate taxation, etc. prescribed in Article 15, paragraph (1) of the Act pertaining to the trustee business operator prescribed in Article 15, paragraph (3) of the Act (".
Article 28, paragraph (14)（法人課税信託等の受託者に関する特例）Special Provisions on Trustees of Trusts Subject to Corporate Taxation, etc.Added
Where the own-assets business operator of a trust subject to corporate taxation, etc. is a seller of specified low-value assets, the trustee business operator of that trust subject to corporate taxation, etc. is deemed to have received the registration under Article 57-7, paragraph (1) of the Act, and the provisions of the Act and this Cabinet Order apply. In this case, in Article 8-2, paragraph (2), item (i) of the Act, the phrase "seller of specified low-value assets" is deemed to be replaced with "the own-assets business operator prescribed in Article 15, paragraph (4) of the trust subject to corporate taxation, etc. prescribed in paragraph (1) of that Article pertaining to the trustee business operator prescribed in paragraph (3) of that Article", and in Article 57-8, item (i) of the Act, the phrase "that seller of specified low-value assets" is deemed to be replaced with "the own-assets business operator prescribed in Article 15, paragraph (4) of the trust subject to corporate taxation, etc. prescribed in paragraph (1) of that Article pertaining to the trustee business operator prescribed in paragraph (3) of that Article that made that transfer of specified low-value assets".
With regard to the application of the provisions of the Act on General Rules for National Taxes to a public interest trust prescribed in the proviso to Article 14, paragraph (1) of the Act that has been subject to the application of Article 15, paragraph (1) of the Act, the phrase "grounds" in Article 7-2, paragraphs (1) and (2) (Succession to the Obligation to Pay National Tax Pertaining to a Trust) of that Act is deemed to be replaced with "grounds or the specified ground for termination prescribed in Article 56, paragraph (1) of the Trust Act as applied with terms replaced pursuant to Article 33, paragraph (3) (Application of the Trust Act) of the Act on Public Interest Trusts (Act No. 30 of 2024)".
Beyond what is provided for in the preceding paragraphs, matters necessary for the application of the provisions of the Act or this Cabinet Order with respect to a trustee business operator or an own-assets business operator are specified by Ministry of Finance Order.
The day a law or an amendment starts to apply. It is often months or years after promulgation, so that people have time to prepare. The Ministry of Justice's English usually says a law "comes into force" or "comes into effect", and sometimes calls the day its "enforcement date". Its "enforcement" more often means the word's other sense, carrying a law out, as in an Order for Enforcement (施行令), the Cabinet Order (政令) that sets out the details for carrying out an Act.
English of the wording before and after the change
Machine translation, not official
English translation
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English translation
Machine translation, corrected on review, not official
Before this amendment: paragraph (14) (第十四項)
Renumbered article繰下げ・繰上げ
An amending law usually leaves every article's number alone: a new article takes a branch number such as Article 32-2, and a repealed one leaves 削除 (Deleted) at its number. Sometimes it moves a run of articles to new numbers instead — 繰下げ (moving them down) to make room, or 繰上げ (moving them up) to close a gap. The words of a moved article need not change, but books, court decisions and contracts written before cite it by its old number. This site marks a moved article with the number it had before the amendment: Act No. 53 of 2023 (令和五年法律第五十三号) makes Article 55 of the Act on Land and Building Leases (借地借家法) Article 58.
An amending law usually leaves every article's number alone: a new article takes a branch number such as Article 32-2, and a repealed one leaves 削除 (Deleted) at its number. Sometimes it moves a run of articles to new numbers instead — 繰下げ (moving them down) to make room, or 繰上げ (moving them up) to close a gap. The words of a moved article need not change, but books, court decisions and contracts written before cite it by its old number. This site marks a moved article with the number it had before the amendment: Act No. 53 of 2023 (令和五年法律第五十三号) makes Article 55 of the Act on Land and Building Leases (借地借家法) Article 58.