①In the case where the amount of income for each business year entered in a Final Return filed by a domestic corporation exceeds the amount of income that should be the tax base for the business year, when the excess amount includes any amount based on accounting conducted by disguising facts, the district director may refrain from making a Reassessment with regard to the corporation tax on income for the business year until the domestic corporation makes corrective accounting with regard to the facts in a business year after the business year and files a Final Return for the business year in which it made the corrective accounting.

②With regard to the application of the provisions of Article 28, paragraph (2) (Procedures for Reassessment or Determination) of the Act on General Rules for National Taxes in the case where the district director makes a Reassessment set forth in Article 135, paragraph (1) (Special Provisions on Refund of Corporation Tax upon Reassessment after Excessive Return Based on Fictitious Accounting), the phrase "the following amounts" in item (iii) of that paragraph is deemed to be replaced with "the following amounts, and those of the amounts listed in (d) or (e) to which the provisions of Article 135, paragraph (1) or (2) (Special Provisions on Refund of Corporation Tax upon Reassessment after Excessive Return Based on Fictitious Accounting) of the Corporation Tax Act apply".

①In the case where the district director of the tax office makes a Reassessment with regard to the tax base of corporation tax or the net operating loss pertaining to a Blue Return that a domestic corporation has filed, they examine the domestic corporation's books and documents and may make the Reassessment only in the case where they find any errors in the calculation of the tax base of corporation tax or the net operating loss pertaining to the Blue Return, based on the results of the examination; provided, however, that in the case where the matters entered in the Blue Return and the documents attached thereto clearly reveal that the calculation of the tax base or the net operating loss is not in accordance with the provisions of this Act or there are any other errors in the calculation, the district director of the tax office is not precluded from making a Reassessment without examining the books and documents.

②In the case where the district director of the tax office makes a Reassessment with regard to the tax base of corporation tax or the net operating loss pertaining to a Blue Return that a domestic corporation has filed, or with regard to the tax base of corporation tax on the international minimum tax amount for each covered fiscal year, corporation tax on the international minimum tax residual amount for each covered fiscal year, or corporation tax on the domestic minimum tax amount for each covered fiscal year of a domestic corporation, they must additionally enter the reason for the Reassessment in a written notice of Reassessment as prescribed in Article 28, paragraph (2) (Procedures for Reassessment or Determination) of the Act on General Rules for National Taxes.

In the case where the district director of the tax office makes a Reassessment or determination with regard to corporation tax related to a domestic corporation, except for the case where they make a Reassessment with regard to the tax base of corporation tax (in the case where the domestic corporation is a group tax sharing corporation (including a domestic corporation that was a group tax sharing corporation; hereinafter the same applies in this Article), excluding corporation tax for each business year from the business year specified in the relevant item of Article 127, paragraph (1) as read by replacing terms pursuant to the provisions of Article 127, paragraph (3) or paragraph (4) (Rescission of Approval to File a Blue Return) to the previous business year of the first business year, among the business years after that business year, for which it files a return other than a Blue Return) or the net operating loss pertaining to a Blue Return that a domestic corporation has filed, or with regard to the tax base of corporation tax on the international minimum tax amount for each covered fiscal year, corporation tax on the international minimum tax residual amount for each covered fiscal year, or corporation tax on the domestic minimum tax amount for each covered fiscal year of a domestic corporation, they may make a Reassessment or determination by way of estimating the tax base of corporation tax (in the case of making a Reassessment, estimating the tax base or the net operating loss) related to the domestic corporation, in light of any increases and decreases in assets or liabilities, revenue or expenses, production volumes, sales volumes or other transaction volumes, the number of employees and other matters concerning the size of the business of the domestic corporation (in the case where the domestic corporation is a group tax sharing corporation, including other group tax sharing corporations).

①In the case where the district director of the tax office makes a reassessment or determination with regard to corporation tax related to a corporation listed as follows, when it is found that any acts conducted or calculations made by the corporation would, if allowed, unreasonably reduce the burden of corporation tax, they may calculate the tax base of corporation tax related to the corporation, the net operating loss , or the amount of corporation tax, based on their own recognition, notwithstanding the acts or calculations:

②In the case referred to in the preceding paragraph, the determination as to whether a domestic corporation falls under the category of corporations listed in the items of the paragraph is to be based on the circumstances as of the time when the acts or calculation prescribed in the paragraph were actually conducted or made.

③The provisions of paragraph (1) apply mutatis mutandis to the case where a reassessment or determination as prescribed in the paragraph is made and when the provisions of Article 157, paragraph (1) (Denial of Acts or Calculation by Family Companies) of the Income Tax Act, Article 64, paragraph (1) (Denial of Acts or Calculation by Family Companies) of the Inheritance Tax Act, or Article 32, paragraph (1) (Denial of Acts or Calculation by Family Companies) of the Land Value Tax Act were applied to the acts conducted or calculation made by a corporation listed in the items of paragraph (1).

In the case where the district director of the tax office makes a Reassessment or determination with regard to corporation tax related to a corporation listed as follows that was involved in a merger, company split, contribution in kind to the capital of the receiving corporation, distribution in kind (meaning a distribution in kind as prescribed in Article 2, item (xii)-5-2 (Definitions)), share exchange, etc. or share transfer (hereinafter referred to as a "merger, etc." in this Article), when it is found that any acts conducted or calculations made by the corporation would, if allowed, unreasonably reduce the burden of corporation tax, due to a decrease in the amount of profit or an increase in the net operating loss on the transfer of assets and liabilities transferred as a result of a merger, etc., an increase in the amount to be credited from corporation tax, a decrease in the amount of profit or an increase in the net operating loss on the transfer of shares (including capital contributions; the same applies in item (ii)) of a corporation listed in item (i) or item (ii), a decrease in the amount of deemed dividend (meaning the amount deemed to be the amount listed in Article 23, paragraph (1), item (i) or item (ii) (Exclusion of Dividends Received from Gross Profits) pursuant to the provisions of Article 24, paragraph (1) (The Amount Deemed to Be Dividends)), or due to other grounds, they may calculate the tax base of corporation tax related to the corporation, the net operating loss, or the amount of corporation tax, based on their own recognition, notwithstanding the acts or calculation:

In the case where the district director makes a Reassessment or determination with regard to corporation tax on income for each business year of a group tax sharing corporation, when it is found that any acts conducted or calculations made by the group tax sharing corporation or another group tax sharing corporation would, if allowed, unreasonably reduce the burden of corporation tax, due to an increase in the amount to be deducted from the amount of income for each business year, an increase in the amount to be credited from corporation tax, a decrease in the amount of profit or an increase in the amount of loss on the transfer of assets to another group tax sharing corporation, or due to other grounds, the district director may calculate the tax base of corporation tax related to the group tax sharing corporation, the net operating loss, or the amount of corporation tax, based on the district director's own recognition, notwithstanding the acts or calculations.

①In the case where a Reassessment (including a decision or determination on an appeal, or a judgment on a lawsuit, against a disposition on a request for Reassessment of the corporation tax (meaning a request for Reassessment under the provisions of Article 23, paragraph (1) (Request for Reassessment) of the Act on General Rules for National Taxes; the same applies in the following paragraph and the following Article); hereinafter referred to as a "Reassessment or similar decision" in this paragraph and the following paragraph) has been made with regard to corporation tax pertaining to an interim return (limited to one containing the matters listed in the items of Article 72, paragraph (1) (Matters to be Entered in Interim Return in the Case of Provisional Settlement of Accounts)) or a Final Return filed by a domestic corporation, when the amount listed in Article 72, paragraph (4), item (i) or Article 74, paragraph (1), item (iii) (Final Returns) has increased as a result of the Reassessment or similar decision, the district director refunds to the domestic corporation the amount of tax equivalent to the increased portion.

②In the case of calculating the amount of interest on a refund with regard to a refund pursuant to the provisions of the preceding paragraph, the period set forth in Article 58, paragraph (1) (Interest on Refund) of the Act on General Rules for National Taxes, which is the basis of the calculation, is to be the period from the day on which one month has elapsed from the day following the date of the Reassessment or similar decision set forth in the preceding paragraph (in the case where the Reassessment or similar decision is a Reassessment based on a request for Reassessment, or a decision or determination on an appeal or a judgment on a lawsuit against a disposition on a request for Reassessment, the earlier of the day on which three months have elapsed from the day following the date of the request for Reassessment and the day on which one month has elapsed from the day following the date of the Reassessment or similar decision) up to the day on which payment of the refund is decided or the day on which the refund is appropriated (in the case where appropriation has become possible before the date of appropriation, the day on which it becomes possible).

③In the case where a refund pursuant to the provisions of paragraph (1) is appropriated for the unpaid portion of the corporation tax on income for the business year pertaining to an interim return set forth in the paragraph or for the business year pertaining to a Final Return set forth in the paragraph, interest on a refund is not added to the portion of the refund to be used for appropriation and any delinquent tax and interest tax are to be exempted with regard to the portion of the corporation tax that is to be appropriated.

④Beyond what is provided for in the preceding two paragraphs, methods for appropriation of a refund (including interest on a refund related thereto) pursuant to the provisions of paragraph (1), and other necessary matters concerning the application of the provisions of the paragraph are specified by Cabinet Order.

①With regard to an ordinary corporation which is a domestic corporation that has filed an interim return, in the case where a determination under the provisions of Article 25 (Determination) of the Act on General Rules for National Taxes has been made with regard to corporation tax for the business year pertaining to the interim return, when there is any amount listed in Article 74, paragraph (1), item (v) (Final Returns) related to the determination, the district director of the tax office refunds an interim payment equivalent to the amount to the ordinary corporation.

②With regard to an ordinary corporation which is a domestic corporation that has filed an interim return, in the case where a Reassessment (including a decision or determination on an appeal, or a judgment on a lawsuit, against a disposition, etc. concerning the corporation tax (meaning a disposition on a request for Reassessment or a determination under the provisions of Article 25 of the Act on General Rules for National Taxes); hereinafter referred to as a "Reassessment or similar decision" in this paragraph and paragraph (4), item (ii)) has been made with regard to corporation tax for the business year pertaining to the interim return, when any amount listed in Article 74, paragraph (1), item (v) has increased as a result of the Reassessment or similar decision, the district director of the tax office refunds an interim payment equivalent to the amount of the increase to the ordinary corporation.

③In the case where the district director of the tax office makes a refund pursuant to the provisions of the preceding two paragraphs, when any delinquent tax has been paid with regard to the interim payment related to an interim return as prescribed in these provisions, they also refund the amount calculated, as specified by Cabinet Order, as the portion of the delinquent tax that corresponds to the interim payment to be refunded under these provisions.

④In the case of calculating the amount of interest on a refund with regard to a refund under the provisions of paragraph (1) or paragraph (2), the period set forth in Article 58, paragraph (1) (Interest on Refund) of the Act on General Rules for National Taxes, which is the basis of the calculation, is to be the period from the day following the day on which the interim payment to be refunded pursuant to the provisions of paragraph (1) or paragraph (2) was paid (in the case where the interim payment was paid prior to the due date for payment, from the day following the due date for payment) up to the day on which payment of the refund is decided or the day on which the refund is appropriated (in the case where appropriation has become possible before the date of appropriation, up to the day on which it becomes possible; referred to as the "date of appropriation" in item (ii), (b)); provided, however, that the number of days specified in each of the following items in accordance with the category of refund listed in the respective item is not included in the period:

⑤In the case where a refund pursuant to the provisions of paragraph (1) or paragraph (2) is appropriated for the unpaid portion of the corporation tax on income for the business year related to the interim payment, which was used as the basis of the calculation of the amount of the refund, interest on the refund is not added to the portion of the refund to be used for appropriation and any delinquent tax and interest tax are exempted with regard to the portion of the corporation tax that is to be appropriated.

⑥Interest on a refund is not added to a refund pursuant to the provisions of paragraph (3).

⑦Beyond what is provided for in the preceding three paragraphs, methods for appropriation of a refund (including interest on a refund related thereto) pursuant to the provisions of paragraph (1) or paragraph (2), and other necessary matters concerning the application of the provisions of paragraphs (1) through (3) are specified by Cabinet Order.

①In the case where the amount of income for each business year entered in a Final Return filed by a domestic corporation exceeds the amount of income that should be the tax base for the business year and the excess amount includes any amount based on accounting conducted by disguising facts, when the district director has made a Reassessment with regard to corporation tax on income for the business year (excluding the case where any of the facts listed in the items of paragraph (3) or the items of paragraph (4) has arisen with regard to the domestic corporation during the period from the last day of the business year to the day preceding the date of the Reassessment, and the case where any such fact has arisen with regard to the acquiring corporation in a qualified merger in which the domestic corporation is the acquired corporation during the period from the date of the qualified merger to the day preceding the date of the Reassessment), the portion of the amount paid as corporation tax on income for the business year that is specified by Cabinet Order which decreases as a result of the Reassessment and pertains to the amount so disguised in the accounting (hereinafter referred to as the "corporation tax paid on fictitious accounting" in this Article) is not refunded, except for the amount of a refund under the provisions of the following paragraph, paragraph (3) or paragraph (7) in the case where those provisions apply.

②In the case referred to in the preceding paragraph, when there is any amount of corporation tax on income for each business year that commenced within one year before the first day of the business year containing the date of the Reassessment set forth in the preceding paragraph of the domestic corporation set forth in that paragraph (or, in the case where the domestic corporation has been dissolved as a result of a qualified merger by the day preceding the date of the Reassessment set forth in that paragraph, the acquiring corporation in the qualified merger; hereinafter the same applies in this paragraph) (excluding the amount of penalty tax) which has been determined as of the day preceding the date of the Reassessment (hereinafter referred to as the "amount of determined corporation tax" in this paragraph), the district director refunds to the domestic corporation the portion of the corporation tax paid on fictitious accounting pertaining to the Reassessment up to the amount of determined corporation tax (excluding any portion that has already been used as the basis for the calculation of an amount to be refunded under the provisions of this paragraph).

③In the case where, with regard to a domestic corporation to which the provisions of paragraph (1) have been applied (or, in the case where the domestic corporation has been dissolved as a result of a qualified merger, the acquiring corporation in the qualified merger; hereinafter referred to as an "applicable corporation" in this Article), the due date for filing a return under Article 74, paragraph (1) (Final Returns) for the business year containing the day on which five years have elapsed from the first day of the business year containing the date of the Reassessment set forth in that paragraph (or, in the case where the Reassessment was made with regard to corporation tax on income for each business year of an acquired corporation in the qualified merger before the date of the qualified merger, the first day of the business year of the acquired corporation containing the date of the Reassessment) (or, in the case where any of the facts listed in the following items has arisen with regard to the applicable corporation during the period from the date of the Reassessment to the last day of the business year containing the day on which those five years have elapsed, the due date specified in the relevant item; hereinafter referred to as the "final due date for filing" in this paragraph and paragraph (8)) has arrived (or, in the case where no return pertaining to the final due date for filing has been filed by the final due date for filing, in the case where a return filed after the due date pertaining to that return has been filed or a determination has been made with regard to corporation tax for the business year pertaining to that return), the district director refunds to the applicable corporation the corporation tax paid on fictitious accounting pertaining to the Reassessment (excluding the amount that has already become refundable pursuant to the provisions of the preceding paragraph, this paragraph or paragraph (7) and the amount deducted pursuant to the provisions of Article 70 (Corporation Tax Credit Due to a Reassessment after Fictitious Accounting)).

④In the case where any of the following facts has arisen with regard to an applicable corporation, the applicable corporation may, within one year on or after the day on which the fact arose, make a claim to the competent district director with jurisdiction over the place for tax payment for a refund of the corporation tax paid on fictitious accounting pertaining to the application (excluding the amount that has already become refundable pursuant to the provisions of the preceding two paragraphs or paragraph (7) and the amount deducted pursuant to the provisions of Article 70; the same applies in paragraphs (6) and (7)):

⑤In the case where there has been a Reassessment that decreases the amount of income for each business year of a domestic corporation, which accompanies a Reassessment made with regard to corporation tax on income for a business year of the domestic corporation that ended before the first day of the relevant business year (including a Reassessment made with regard to corporation tax on income for a business year of an acquired corporation in a qualified merger in which the domestic corporation is the acquiring corporation that ended before the date of the qualified merger; hereinafter referred to as the "original Reassessment" in this paragraph) (hereinafter referred to as a "consequential Reassessment" in this paragraph), when the portion of the amount of income that decreases as a result of the consequential Reassessment includes any amount pertaining to an amount disguised in the accounting by disguising facts in the business year pertaining to the original Reassessment, the provisions of the preceding paragraphs apply by deeming that amount to be an amount based on accounting disguised by the domestic corporation in the relevant business year.

⑥An applicable corporation that intends to make a claim for a refund under the provisions of paragraph (4) must submit a refund claim form stating the corporation tax paid on fictitious accounting for which it seeks the refund, the basis of the calculation thereof, and any other matters as specified by Ministry of Finance Order, to the competent district director with jurisdiction over the place for tax payment.

⑦When a refund claim form set forth in the preceding paragraph has been submitted, the district director examines the facts pertaining to the claim and other necessary matters and, based on the examination, refunds the corporation tax paid on fictitious accounting to the applicable corporation that made the claim, or notifies it in writing that there are no grounds for filing a claim.

⑧In the case of calculating the amount of interest on a refund with regard to a refund under the provisions of paragraph (2), paragraph (3) or the preceding paragraph, the period set forth in Article 58, paragraph (1) (Interest on Refund) of the Act on General Rules for National Taxes, which is the basis of the calculation, is to be the period from the day on which one month has elapsed from the day following the date of the Reassessment set forth in paragraph (1) (for a refund under the provisions of paragraph (3), the day following the final due date for filing set forth in that paragraph (or, in the case where a return filed after the due date set forth in that paragraph has been filed, the date of its filing, and in the case where a determination set forth in that paragraph has been made, the date of the determination), and for a refund under the provisions of the preceding paragraph, the day on which three months have elapsed from the day following the day on which the claim for a refund under the provisions of paragraph (4) was made) up to the day on which payment of the refund is decided or the day on which the refund is appropriated (in the case where appropriation has become possible before the date of appropriation, up to the day on which it becomes possible).

⑨In the case referred to in paragraph (1), when the amount listed in Article 74, paragraph (1), item (v) has increased as a result of the Reassessment set forth in that paragraph, the provisions of paragraph (2) of the preceding Article do not apply to the portion of the increased amount up to the corporation tax paid on fictitious accounting pertaining to the Reassessment; provided, however, that this does not apply to the application of the provisions of paragraph (3) of that Article in the case where there is any delinquent tax prescribed in that paragraph.