The term "domestic source income" as used in this Part means any of the following:
この編において「国内源泉所得」とは、次に掲げるものをいう。
in the case where a foreign corporation carries on business through a permanent establishment, the income that should be attributed to the permanent establishment if the permanent establishment were an enterprise carrying on business independently of the foreign corporation, taking into account the functions performed by the permanent establishment, the assets used by the permanent establishment, internal dealings between the permanent establishment and the head office, etc. of the foreign corporation (meaning the head office, branch office, factory or any other establishment equivalent thereto specified by Cabinet Order of the foreign corporation, other than the permanent establishment; the same applies in the following paragraph and paragraph (2) of the following Article), and other circumstances (including income arising from the transfer of the permanent establishment);
income arising from the management or holding of assets located in Japan (excluding income falling under Article 161, paragraph (1), items (viii) through (xi) and items (xiii) through (xvi) (Domestic Source Income) of the Income Tax Act);
国内にある資産の運用又は保有により生ずる所得（所得税法第百六十一条第一項第八号から第十一号まで及び第十三号から第十六号まで（国内源泉所得）に該当するものを除く。）
income prescribed by Cabinet Order as arising from the transfer of assets located in Japan;
国内にある資産の譲渡により生ずる所得として政令で定めるもの
consideration received by a corporation which conducts a business that has as its main content the provision of personal services in Japan and which is specified by a Cabinet Order, for the provision of the personal services;
国内において人的役務の提供を主たる内容とする事業で政令で定めるものを行う法人が受ける当該人的役務の提供に係る対価
consideration for the lending of real estate located in Japan, any right on real estate located in Japan or a right of quarrying pursuant to the provisions of the Quarrying Act (Act No. 291 of 1950) (including the establishment of superficies or a right of quarrying or any other act carried out for having another person use real estate, any right on real estate or right of quarrying), the establishment of a mining lease pursuant to the provisions of the Mining Act (Act No. 289 of 1950) or the lending of a vessel or aircraft to a resident as prescribed in Article 2, paragraph (1), item (iii) of the Income Tax Act (Definitions) or a domestic corporation;
国内にある不動産、国内にある不動産の上に存する権利若しくは採石法（昭和二十五年法律第二百九十一号）の規定による採石権の貸付け（地上権又は採石権の設定その他他人に不動産、不動産の上に存する権利又は採石権を使用させる一切の行為を含む。）、鉱業法（昭和二十五年法律第二百八十九号）の規定による租鉱権の設定又は所得税法第二条第一項第三号（定義）に規定する居住者若しくは内国法人に対する船舶若しくは航空機の貸付けによる対価
beyond what is set forth in the preceding items, income prescribed by Cabinet Order as income whose source is in Japan.
The internal dealings prescribed in item (i) of the preceding paragraph mean transfers of assets, provision of services or other facts that took place between the permanent establishment and the head office, etc. of a foreign corporation, which would be found to constitute sales of assets, purchases of assets, provision of services or other transactions (excluding guarantees of obligations pertaining to the borrowing of funds, acceptance of reinsurance for insurance liability under insurance contracts, and other transactions specified by Cabinet Order as being similar thereto) between independent enterprises if similar facts had occurred between those enterprises.
In the case where a foreign corporation having a permanent establishment carries on a business of transportation by vessel or aircraft both in Japan and outside Japan, the income specified by Cabinet Order as income that should arise from operations conducted in Japan, out of the income arising from that business, is to be the income listed in paragraph (1), item (i).