This Act comes into effect on the date of promulgation; provided, however, that the provisions set forth in the following items come into effect on the dates specified in those items:

Except as otherwise provided for in these Supplementary Provisions, the provisions of the Corporation Tax Act as amended by Article 2 (hereinafter referred to as the "New Corporation Tax Act") apply to corporation tax on income for business years of a corporation (including an association or foundation without juridical personality prescribed in Article 2, item (viii) of the New Corporation Tax Act; the same applies hereinafter) beginning on or after April 1, 2012 and to corporation tax on consolidated income for consolidated business years of a consolidated corporation beginning on or after that date, and the provisions then in force continue to govern corporation tax on income for business years of a corporation that began before that date and corporation tax on consolidated income for consolidated business years of a consolidated corporation that began before that date.

The provisions of Article 23, paragraph (7) and Article 23-2, paragraphs (3) and (4) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the Final Return, etc. (meaning a return under Article 71, paragraph (1) of the New Corporation Tax Act which states the matters listed in the items of Article 72, paragraph (1) of the New Corporation Tax Act, and a return under Article 74, paragraph (1) of the New Corporation Tax Act; the same applies hereinafter up to Article 17 of the Supplementary Provisions) arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the Final Return, etc. arrived before the Effective Date.

The provisions of Article 37, paragraphs (9) and (10) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the Final Return, etc. arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the Final Return, etc. arrived before the Effective Date.

①With regard to the calculation of the amount of income for each business year of a corporation beginning during the period from April 1, 2012 to March 31, 2015 (referred to as a "business year under the transitional measures" in the following paragraph and paragraph (3)), the provisions of Article 52 of the Corporation Tax Act prior to the amendment by Article 2 (hereinafter referred to as the "Former Corporation Tax Act") remain in force. In this case, the phrase "amount calculated as specified by Cabinet Order" in paragraphs (1) and (2) of that Article is deemed to be replaced with "amount equivalent to three-quarters of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2012 to March 31, 2013, with "amount equivalent to two-quarters of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2013 to March 31, 2014, and with "amount equivalent to one-quarter of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2014 to March 31, 2015.

②With regard to individually assessed monetary claims prescribed in Article 52, paragraph (1) of the New Corporation Tax Act, in the case where a corporation is subject to the application of the provisions of that paragraph or paragraph (5) of that Article with respect to those individually assessed monetary claims in a business year under the transitional measures, the provisions of Article 52, paragraphs (1) and (5) of the Former Corporation Tax Act, which remain in force pursuant to the provisions of the preceding paragraph, do not apply to those individually assessed monetary claims in the business year under the transitional measures in which it is subject to that application.

③In a business year under the transitional measures in which a corporation is subject to the application of the provisions of Article 52, paragraph (2) or (6) of the New Corporation Tax Act, the provisions of Article 52, paragraphs (2) and (6) of the Former Corporation Tax Act, which remain in force pursuant to the provisions of paragraph (1), do not apply.

④The amount of the reserve for bad debts prescribed in the provisions of Article 52, paragraph (1) or (2) of the Former Corporation Tax Act, which remain in force pursuant to the provisions of paragraph (1), that was included in the amount of deductible expenses, when calculating the amount of income for the previous business year of the business year of a corporation first beginning on or after April 1, 2015, pursuant to those provisions, is included in the amount of gross profit, when calculating the amount of income for that business year first beginning on or after that date.

⑤The amount of the reserve for bad debts that a merging corporation, etc. prescribed in Article 52, paragraph (8) of the Former Corporation Tax Act, which remains in force pursuant to the provisions of paragraph (1), has taken over pursuant to the provisions of that paragraph, or the amount of the interim individual reserve for bad debts prescribed in paragraph (5) of that Article or the amount of the interim collective reserve for bad debts prescribed in paragraph (6) of that Article, in a business year of the merging corporation, etc. beginning on or after April 1, 2015, is included in the amount of gross profit, when calculating the amount of income for that business year.

⑥In the case referred to in paragraph (1), with regard to the application of the provisions of Article 55-3, paragraph (10) and Article 58, paragraph (14) of the Act on Special Measures Concerning Taxation as amended by Article 10 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014), the phrase "Corporation Tax Act" in these provisions is deemed to be replaced with "Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. to Build a Tax System Responding to Changes in the Economic and Social Structure (Act No. 114 of 2011), which remains in force pursuant to the provisions of Article 13, paragraph (1) of the Supplementary Provisions of that Act".

The provisions of Article 57 (excluding the proviso to paragraph (1), paragraph (5) and paragraph (11)) and Article 58 (excluding the proviso to paragraph (1), paragraph (3) and paragraph (6)) of the New Corporation Tax Act apply to a net operating loss incurred in a business year of a corporation that ended on or after April 1, 2008, and the provisions then in force continue to govern a net operating loss incurred in a business year of a corporation that ended before that date.

The provisions of Article 59, paragraphs (4) and (5) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the Final Return, etc. arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the Final Return, etc. arrived before the Effective Date.

The provisions then in force continue to govern corporation tax of a cooperative, etc. set forth in Article 60-2, paragraph (1) of the Former Corporation Tax Act for which the due date for filing the return under Article 74, paragraph (1) of the Former Corporation Tax Act arrived before the Effective Date.

The provisions of Article 68, paragraph (3) and Article 69, paragraphs (10) through (12) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the Final Return, etc. arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the Final Return, etc. arrived before the Effective Date.

The provisions of Article 80-2 of the New Corporation Tax Act apply to a request for Reassessment prescribed in Article 80-2 of the New Corporation Tax Act concerning corporation tax for which the due date for filing the return under Article 74, paragraph (1) of the New Corporation Tax Act arrives on or after the Effective Date, and the provisions then in force continue to govern a request for Reassessment prescribed in Article 80-2 of the Former Corporation Tax Act concerning corporation tax for which the due date for filing the return under Article 74, paragraph (1) of the Former Corporation Tax Act arrived before the Effective Date.

①With regard to the calculation of the amount of consolidated income for each consolidated business year of a consolidated corporation beginning during the period from April 1, 2012 to March 31, 2015, the phrase "(Calculation of the Amount of Income for Each Business Year)" in Article 81-3, paragraph (1) of the New Corporation Tax Act is deemed to be replaced with "(Calculation of the Amount of Income for Each Business Year) and the provisions of Article 52 (Bad Debt Reserves) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. to Build a Tax System Responding to Changes in the Economic and Social Structure (Act No. 114 of 2011), which remains in force pursuant to the provisions of Article 13, paragraph (1) (Transitional Measures Concerning Bad Debt Reserves) of the Supplementary Provisions of that Act".

②The amount that would be the amount of gross profit if the period of a consolidated business year of a consolidated corporation were regarded as the business year set forth in Article 22, paragraph (1) of the New Corporation Tax Act and the amount of income for that business year were calculated pursuant to the provisions of Article 13, paragraph (4) or (5) of the Supplementary Provisions is to be included in the individual amount of gross profit prescribed in Article 81-3, paragraph (1) of the New Corporation Tax Act.

③In the case referred to in paragraph (1), with regard to the application of the provisions of Article 68-43-3, paragraph (9) and Article 68-61, paragraph (13) of the Act on Special Measures Concerning Taxation as amended by Article 10 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014), the phrase "Corporation Tax Act" in these provisions is deemed to be replaced with "Corporation Tax Act with the terms replaced pursuant to the provisions of Article 19, paragraph (1) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. to Build a Tax System Responding to Changes in the Economic and Social Structure (Act No. 114 of 2011; hereinafter referred to as the 'Amending Act' in this paragraph)", and the phrase "that Act" with "Corporation Tax Act prior to the amendment by Article 2 of the Amending Act, which remains in force pursuant to the provisions of Article 13, paragraph (1) of the Supplementary Provisions of the Amending Act".

The provisions of Article 81-4, paragraph (7) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the consolidated tax return, etc. (meaning a return under Article 81-19, paragraph (1) of the New Corporation Tax Act which states the matters listed in the items of Article 81-20, paragraph (1) of the New Corporation Tax Act, and a return under Article 81-22, paragraph (1) of the New Corporation Tax Act; the same applies hereinafter up to Article 23 of the Supplementary Provisions) arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the consolidated tax return, etc. arrived before the Effective Date.

The provisions of Article 37, paragraphs (9) and (10) of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 81-6, paragraph (6) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the consolidated tax return, etc. arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the consolidated tax return, etc. arrived before the Effective Date.

The provisions of Article 81-9 of the New Corporation Tax Act (excluding the proviso to paragraph (1) and paragraph (8)) apply to a consolidated net operating loss incurred in a consolidated business year of a consolidated corporation that ended on or after April 1, 2008, and the provisions then in force continue to govern a consolidated net operating loss incurred in a consolidated business year of a consolidated corporation that ended before that date.

The provisions of Article 81-14, paragraph (2) and Article 81-15, paragraphs (9) through (11) of the New Corporation Tax Act apply to corporation tax for which the due date for filing the consolidated tax return, etc. arrives on or after the Effective Date, and the provisions then in force continue to govern corporation tax for which the due date for filing the consolidated tax return, etc. arrived before the Effective Date.

The provisions of Article 82 of the New Corporation Tax Act apply to a request for Reassessment prescribed in Article 82 of the New Corporation Tax Act concerning corporation tax for which the due date for filing the return under Article 81-22, paragraph (1) of the New Corporation Tax Act arrives on or after the Effective Date, and the provisions then in force continue to govern a request for Reassessment prescribed in Article 82 of the Former Corporation Tax Act concerning corporation tax for which the due date for filing the return under Article 81-22, paragraph (1) of the Former Corporation Tax Act arrived before the Effective Date.

With regard to questions or inspections conducted for a corporation on or before December 31, 2012 pursuant to the provisions of Article 153 of the Former Corporation Tax Act (including as applied mutatis mutandis pursuant to Article 155 of the Former Corporation Tax Act; the same applies hereinafter in this Article) (including those pertaining to an investigation continued after that date (limited to an investigation for which questions or inspections under Article 153 of the Former Corporation Tax Act pertaining to that investigation had been conducted for that corporation on or before that date; referred to as an "investigation covered by the transitional measures" in this Article)), and questions or inspections conducted on or before that date pursuant to the provisions of Article 154, paragraph (1) or (2) of the Former Corporation Tax Act (including those pertaining to that investigation covered by the transitional measures) for a person found to be obligated to make a payment of money or a transfer of goods, or a person found to be entitled to receive a payment of money or a transfer of goods, as prescribed in Article 154, paragraph (1) or (2) of the Former Corporation Tax Act (including as applied mutatis mutandis pursuant to Article 155 of the Former Corporation Tax Act; the same applies hereinafter in this Article), the provisions then in force continue to govern.

With regard to the application of penal provisions to acts committed before this Act (or, for the provisions set forth in the items of Article 1 of the Supplementary Provisions, those provisions; the same applies hereinafter in this Article) comes into effect and to acts committed after this Act comes into effect in the cases where the provisions then in force continue to govern pursuant to the provisions of these Supplementary Provisions, the provisions then in force continue to govern.

Matters necessary with regard to the application of the provisions of each Act as amended by this Act in the case where the date of promulgation of this Act falls after April 1, 2011 (including the replacement of terms in the provisions of these Supplementary Provisions) and other transitional measures necessary for the smooth enforcement of this Act are specified by Cabinet Order.

Beyond what is provided for in these Supplementary Provisions, transitional measures necessary in connection with the enforcement of this Act are specified by Cabinet Order.

The government is to continue to conduct a review toward improving the tax payment environment, from the perspective of contributing to the protection of the interests of taxpayers with respect to national taxes and of ensuring the proper and smooth operation of tax administration.