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.