Article 60-3

①With regard to a corporation showing a loss, etc. as prescribed in Article 57-2, paragraph (1) (Non-application of a Carryover of Losses for a Corporation Showing a Loss, etc. That Is Controlled by Specified Shareholders, etc.) (hereinafter referred to as a "corporation showing a loss, etc." in this paragraph and the following paragraph), the amount specified by Cabinet Order as the amount of loss due to a transfer, revaluation, bad debts, removal or any other grounds (hereinafter referred to as "specified grounds such as transfer" in this paragraph) of specified assets (meaning those specified by Cabinet Order out of the assets held by the corporation showing a loss, etc. as of the first day of the business year containing the date of control and the assets transferred to the corporation showing a loss, etc. as a result of a qualified company split or qualified capital contribution in kind effected on or after the first day of the applicable business year wherein the second person prescribed in Article 57-2, paragraph (1) is the splitting corporation or corporation making a capital contribution in kind, or as a result of a qualified organizational restructuring, etc. (meaning a qualified merger, or a merger that does not fall under a qualified merger and to which the provisions of Article 61-11, paragraph (1) (Profit or Loss from Transactions between Corporations with a Full Controlling Interest) apply, a qualified company split, a qualified capital contribution in kind or a qualified in-kind distribution; hereinafter the same applies in this Article) effected on or after that day wherein the related person prescribed in item (iii) of that paragraph is the acquired corporation, splitting corporation, corporation making a capital contribution in kind or corporation making a distribution in kind; hereinafter the same applies in this Article) that arises during the period from the first day of the applicable business year prescribed in paragraph (1) of that Article (hereinafter referred to as the "applicable business year" in this paragraph) of the corporation showing a loss, etc. until the day on which three years have elapsed from that day (in the case where the day on which three years have elapsed falls after the day on which five years have elapsed from the date of control prescribed in paragraph (1) of that Article, until the day on which five years have elapsed) (in the case where, in any business year ending during that period, the corporation showing a loss, etc. is subject to the provisions of Article 62-9, paragraph (1) (Gains or Losses on the Fair Valuation of Assets Held by Wholly Owned Subsidiary Corporations in a Share Exchange Involved in Non-qualified Share Exchange), Article 64-11, paragraph (1) (Gains or Losses on the Fair Valuation of Assets upon the Start of the Group Tax Sharing System), Article 64-12, paragraph (1) (Gains or Losses on the Fair Valuation of Assets upon Joining the Group Tax Sharing System) or Article 64-13, paragraph (1) (limited to the part pertaining to item (i)) (Gains or Losses on the Fair Valuation of Assets upon Withdrawal from the Group Tax Sharing System, etc.), the period from the first day of the applicable business year until the last day of the business year for which it is subject to those provisions; hereinafter referred to as the "application period" in this paragraph and the following paragraph) (in the case where there is an amount specified by Cabinet Order as the amount of profits due to a transfer, revaluation or any other grounds of specified assets that arises during the application period of the business year containing the day on which the specified grounds such as transfer occurred, the amount that remains after deducting that amount; referred to as the "amount of loss from transfer, etc." in paragraph (3)) is excluded from deductible expenses, when calculating the amount of income of the corporation showing a loss, etc. for each business year.

③Necessary matters concerning the calculation of the amount of loss from transfer, etc. pertaining to specified assets that an acquiring corporation, etc. set forth in the preceding paragraph has received as a result of a qualified organizational restructuring, etc. and other necessary matters concerning the application of the provisions of paragraph (1) are specified by Cabinet Order.