Article 61

①In the case where a domestic corporation has transferred any commodities for short-term trading, etc. (meaning commodities as specified by Cabinet Order as assets acquired for the purpose of profit from short-term price fluctuations (excluding securities) and cryptoassets as prescribed in Article 2, paragraph (14) (Definitions) of the Payment Services Act (Act No. 59 of 2009) (hereinafter referred to as "cryptoassets" in this Article); hereinafter the same applies in this Article), except in the case where the provisions of Articles 62 through 62-5 (Transfer of Assets as a Result of a Merger, etc.) apply, capital gain (meaning the difference between the amount listed in item (i) and the amount listed in item (ii) when the former exceeds the latter) or capital loss (meaning the difference between the amount listed in item (i) and the amount listed in item (ii) when the latter exceeds the former) on the transfer is included in gross profits or deductible expenses, when calculating the amount of income for the business year containing the day on which a contract for the transfer was concluded (or, in the case where the transfer is due to a dividend of surplus or any other grounds specified by Ministry of Finance Order, the day on which the dividend of surplus becomes effective or any other day specified by Ministry of Finance Order):

②With regard to commodities for short-term trading, etc. held by a domestic corporation as of the end of a business year (hereinafter referred to as "at the end of the period" in this paragraph and the following paragraph), the amount evaluated by the method specified in the following items in accordance with the category of commodities for short-term trading, etc. listed in the respective items (for commodities for short-term trading, etc. listed in item (ii), the method selected by the domestic corporation out of the methods specified in that item (or, in the case where it did not select a method, the method listed in (b) of that item)) is to be their fair value at the end of the period.

③In the case where a domestic corporation holds, at the end of the period, any commodities for short-term trading, etc. (limited to those for which the amount evaluated by the fair value method (hereinafter referred to as the "fair value" in this paragraph) is treated as their fair value at the end of the period; hereinafter the same applies in this paragraph and the following paragraph) (for cryptoassets, limited to the case where it holds them on its own account), the valuation gain therefrom (meaning, in the case where the fair value of the commodities for short-term trading, etc. exceeds their book value at the end of the period (hereinafter referred to as the "book value at the end of the period" in this paragraph), the amount of the excess; the same applies in the following paragraph) or the valuation loss therefrom (meaning, in the case where the book value at the end of the period of the commodities for short-term trading, etc. exceeds their fair value, the amount of the excess; the same applies in the following paragraph) is included in gross profits or deductible expenses, when calculating the amount of income for the business year in which that end of the period falls, notwithstanding the provisions of Article 25, paragraph (1) (Valuation Gain on Assets) or Article 33, paragraph (1) (Valuation Loss on Assets).

⑤In the case where a domestic corporation holds any commodities for short-term trading, etc. (excluding cryptoassets; hereinafter the same applies in this paragraph), when it has abolished all of the operations to buy and sell commodities for short-term trading, etc. for the purpose prescribed in paragraph (1), the amount of income of the domestic corporation for each business year is calculated by deeming that the domestic corporation transferred, as of the time of the abolition, the commodities for short-term trading, etc. for their value at that time and acquired assets other than commodities for short-term trading, etc. for their value.

⑥In the case where a domestic corporation holds cryptoassets on its own account, when the cryptoassets have ceased to fall under specified self-issued cryptoassets or any other fact specified by Cabinet Order has occurred, the amount of income of the domestic corporation for each business year is calculated by deeming, as specified by Cabinet Order, that the domestic corporation transferred the cryptoassets and acquired the cryptoassets.

⑦In the case where a domestic corporation has conducted a cryptoasset margin transaction (meaning the buying and selling of cryptoassets conducted by receiving credit from another person; hereinafter the same applies in this Article), when any of the cryptoasset margin transactions has not been settled as of the end of a business year, the amount equivalent to the amount of profit or the amount of loss calculated as specified by Ministry of Finance Order by deeming that the cryptoasset margin transaction was settled at that time (referred to as the "deemed settlement profit or loss" in the following paragraph) is included in gross profits or deductible expenses, when calculating the amount of income for the business year.

⑧In the case where a domestic corporation transfers a contract pertaining to a cryptoasset margin transaction to a succeeding corporation in a company split or a corporation receiving a capital contribution in kind as a result of a qualified company split or qualified capital contribution in kind (hereinafter referred to as a "qualified company split, etc." in this paragraph), the amount equivalent to the deemed settlement profit or loss on the cryptoasset margin transaction that would be calculated under the provisions of the preceding paragraph if the day preceding the date of the qualified company split, etc. were the last day of the business year is included in gross profits or deductible expenses, when calculating the amount of income for the business year containing the date of the qualified company split, etc.

⑨In the case where a domestic corporation has acquired cryptoassets based on a contract pertaining to a cryptoasset margin transaction (excluding the case where the domestic corporation has acquired the cryptoassets based on a contract pertaining to a cryptoasset margin transaction subject to the provisions of Article 61-6, paragraph (1) (Deferment of Profit or Loss by Deferred Hedge Accounting)), the difference between the value of the cryptoassets as of the time of the acquisition and the amount that the domestic corporation paid as the consideration for the acquisition of the cryptoassets based on the contract pertaining to the cryptoasset margin transaction that had caused the acquisition is included in gross profits or deductible expenses, when calculating the amount of income for the business year containing the date of the acquisition.

⑩Methods for calculating the acquisition cost that is to be used as the basis of the calculation of book values per unit of commodities for short-term trading, etc., the type of methods for calculating book values per unit of commodities for short-term trading, etc., procedures to select the calculation methods, procedures to select the method of evaluating commodities for short-term trading, etc. listed in paragraph (2), item (ii), disposition of valuation gain or loss prescribed in paragraph (3) in the following business year, disposition of deemed settlement profit or loss prescribed in paragraph (7) in the following business year, and other necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.