This Act comes into effect on April 1, 2018; provided, however, that the provisions set forth in the following items come into effect on the dates specified respectively in those items:

Unless otherwise provided for in these Supplementary Provisions, the provisions of the Corporation Tax Act as amended by the provisions of Article 2 (hereinafter referred to as "the New Corporation Tax Act") apply to corporation tax on income for business years of corporations (including associations or foundations without juridical personality; the same applies hereinafter) that end on or after the Effective Date and to corporation tax on consolidated income for consolidated business years of consolidated corporations that end on or after the Effective Date, and with regard to corporation tax on income for business years of corporations that ended before the Effective Date and corporation tax on consolidated income for consolidated business years of consolidated corporations that ended before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 2, items (xii)-8, (xii)-11, (xii)-14 and (xii)-16 through (xii)-18 of the New Corporation Tax Act apply to mergers, company splits, contributions in kind, share exchanges, etc. and share transfers carried out on or after the Effective Date, and with regard to mergers, company splits, contributions in kind, share exchanges, etc. and share transfers carried out before the Effective Date, the provisions then in force continue to govern.

①The provisions of Article 2, item (xii)-19 of the New Corporation Tax Act apply to corporation tax on income for business years of foreign corporations that begin on or after January 1, 2019, and with regard to corporation tax on income for business years of foreign corporations that began before that date, the provisions then in force continue to govern.

③In the case where the provisions of Article 2, item (xii)-19 of the New Corporation Tax Act apply pursuant to the provisions of paragraph (1), when a foreign corporation that had no former permanent establishment has come to have a new permanent establishment on January 1, 2019, with regard to the portion of the redemption gains (meaning redemption gains prescribed in Article 67-17, paragraph (4) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) on discount bonds (meaning discount bonds prescribed in Article 41-12-2, paragraph (6), item (i) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) issued before that date by that foreign corporation that had no former permanent establishment which is specified by Cabinet Order as pertaining to the business conducted through that new permanent establishment, the provisions of the Corporation Tax Act and other laws and regulations concerning corporation tax apply by deeming that portion not to fall under the redemption gains on discount bonds that are deemed to be domestic source income listed in Article 138, paragraph (1), item (ii) of the Corporation Tax Act pursuant to the provisions of Article 67-17, paragraph (4) of the Act on Special Measures Concerning Taxation.

④Beyond what is provided for in the preceding two paragraphs, necessary matters concerning the application of the provisions of laws and regulations concerning corporation tax in the case where the provisions of Article 2, item (xii)-19 of the New Corporation Tax Act apply pursuant to the provisions of paragraph (1) are specified by Cabinet Order.

The provisions of Article 24, paragraph (3) of the New Corporation Tax Act apply to mergers and company splits by split-off carried out on or after the Effective Date.

The provisions of Article 41-2 of the New Corporation Tax Act apply to the amount equivalent to the foreign tax adjusted at distribution prescribed in Article 69-2, paragraph (1) of the New Corporation Tax Act that pertains to the amount of income tax on distributions of proceeds from group investment trusts that a domestic corporation receives on or after January 1, 2020.

The provisions of Article 50, paragraph (1) of the New Corporation Tax Act apply to exchanges referred to in that paragraph that a corporation carries out on or after the date specified in Article 1, item (x) of the Supplementary Provisions, and with regard to exchanges referred to in Article 50, paragraph (1) of the Former Corporation Tax Act that a corporation carried out before that date, the provisions then in force continue to govern.

①With regard to the calculation of the amount of income (including the amount of income for the business year containing the Effective Date of a corporation other than a corporation under the transitional measures that has carried out a qualified company split, etc. prescribed in paragraph (4) of that Article that transfers a covered business within the period of that business year before the Effective Date) for a business year (limited to a business year that begins on or before March 31, 2030) that ends on or after the Effective Date of a corporation that, at the time this Act comes into effect, is actually engaged in a covered business prescribed in Article 53, paragraph (1) of the Former Corporation Tax Act (hereinafter referred to as a "covered business" in this paragraph and paragraph (4)) (including a corporation that receives, on or after the Effective Date, a transfer of a covered business actually being conducted at the time this Act comes into effect; hereinafter referred to as a "corporation under the transitional measures" in this paragraph and paragraph (4)), the provisions of that Article (including the cases where calculation is made in accordance therewith pursuant to the provisions of Article 142, paragraph (2) of the Former Corporation Tax Act; the same applies in the following paragraph through paragraph (4)) remain in force. In this case, in Article 53, paragraph (1) of the Former Corporation Tax Act, the phrase "the amount calculated as specified by Cabinet Order" is deemed to be replaced with "the amount equivalent to nine-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2021 to March 31, 2022, with "the amount equivalent to eight-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2022 to March 31, 2023, with "the amount equivalent to seven-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2023 to March 31, 2024, with "the amount equivalent to six-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2024 to March 31, 2025, with "the amount equivalent to five-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2025 to March 31, 2026, with "the amount equivalent to four-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2026 to March 31, 2027, with "the amount equivalent to three-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2027 to March 31, 2028, with "the amount equivalent to two-tenths of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2028 to March 31, 2029, and with "the amount equivalent to one-tenth of the amount calculated as specified by Cabinet Order" for business years beginning during the period from April 1, 2029 to March 31, 2030, and in paragraph (9) of that Article, the phrase "specified ordinary corporation, etc. prescribed in Article 10-3, paragraph (1) (Changes in Scope of Taxable Income, etc.)" is deemed to be replaced with "ordinary corporation or cooperative, etc." and the phrase "that specified ordinary corporation, etc." with "that ordinary corporation or cooperative, etc.".

②The amount in the returned goods adjustment reserve account prescribed in Article 53, paragraph (1) of the Former Corporation Tax Act that has been included in the amount of deductible expenses pursuant to the provisions of that paragraph, which remain in force pursuant to the provisions of the preceding paragraph, when calculating the amount of income for the previous business year of the business year of a corporation that first begins on or after April 1, 2030, is included in the amount of gross profit when calculating the amount of income for that business year that first begins.

③The amount in the returned goods adjustment reserve account that a merging corporation, etc. prescribed in Article 53, paragraph (6) of the Former Corporation Tax Act, as that paragraph remains in force pursuant to the provisions of paragraph (1), has taken over pursuant to the provisions of that paragraph, or the amount in the interim returned goods adjustment reserve account prescribed in paragraph (4) of that Article, in a business year of that merging corporation, etc. that begins on or after April 1, 2030, is included in the amount of gross profit when calculating the amount of income for that business year.

④The amount in the returned goods adjustment reserve account prescribed in Article 53, paragraph (1) of the Former Corporation Tax Act that has been included in the amount of deductible expenses pursuant to the provisions of that paragraph when calculating the amount of income for the previous business year of the business year containing the Effective Date of a corporation (excluding a corporation under the transitional measures) that was engaged in a covered business before the Effective Date, and any other amount specified by Cabinet Order as being equivalent thereto, is included in the amount of gross profit when calculating the amount of income for the business year containing the Effective Date.

⑤Necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.

The provisions of Article 61-2, paragraphs (2) and (9) of the New Corporation Tax Act apply to mergers and share exchanges carried out on or after the Effective Date, and with regard to mergers and share exchanges carried out before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 62, paragraph (1) of the New Corporation Tax Act apply to mergers and company splits carried out on or after the Effective Date, and with regard to mergers and company splits carried out before the Effective Date, the provisions then in force continue to govern.

①With regard to the calculation of the amount of income for a business year (limited to a business year that begins on or before March 31, 2023; referred to as a "business year under the transitional measures" in item (i) of the following paragraph) that ends on or after the Effective Date of a corporation that carried out, before the Effective Date, a sale, etc. of assets prescribed in Article 63, paragraph (1) of the Former Corporation Tax Act (excluding a lease transfer prescribed in Article 63, paragraph (1) of the Corporation Tax Act; hereinafter referred to as a "specified sale of assets" in this Article) that falls under a long-term installment sale, etc. prescribed in Article 63, paragraph (6) of the Former Corporation Tax Act (hereinafter referred to as a "long-term installment sale, etc." in this Article) (including a corporation that received a transfer of a contract pertaining to a specified sale of assets falling under a long-term installment sale, etc. carried out before the Effective Date), the provisions of Article 63, paragraphs (1), (4) through (6) and (9) of the Former Corporation Tax Act (limited to the portion pertaining to specified sales of assets, and including the cases where calculation is made in accordance therewith pursuant to the provisions of Article 142, paragraph (2) of the Former Corporation Tax Act) remain in force. In this case, in Article 63, paragraph (4) of the Former Corporation Tax Act, the phrase "consolidated business year" is deemed to be replaced with "consolidated business year (meaning a consolidated business year prescribed in Article 15-2, paragraph (1) (Meaning of Consolidated Business Year) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020))" and the phrase "consolidated income" with "consolidated income (meaning consolidated income prescribed in Article 2, item (xviii)-4 (Definitions) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020))", and in paragraph (5) of that Article, the phrase "Article 61-13, paragraph (1)" is deemed to be replaced with "Article 61-11, paragraph (1)".

②If the amount of proceeds and the amount of expenses pertaining to a specified sale of assets falling under a long-term installment sale, etc. of a corporation that is subject to the provisions of the main clause of Article 63, paragraph (1) (including the cases where calculation is made in accordance therewith pursuant to the provisions of Article 142, paragraph (2) of the Former Corporation Tax Act; the same applies in the following paragraph) of the Former Corporation Tax Act as it remains in force pursuant to the provisions of the preceding paragraph (hereinafter referred to as the "Former Corporation Tax Act Kept in Force" in this Article) fall under the cases set forth in the following items, that amount of proceeds and amount of expenses (excluding those included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for each business year that began before the first day of the business year specified in the respective items or the amount of consolidated income (meaning consolidated income prescribed in Article 2, item (xviii)-4 of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies hereinafter in this Article) for each consolidated business year (meaning a consolidated business year prescribed in Article 15-2, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies hereinafter in this Article) that began before that day; referred to respectively as "unrecognized revenue" and "unrecognized expenses" in the following paragraph) are included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for the business year specified in the respective items (referred to as the "base business year" in the following paragraph and paragraph (4)):

③If the amount of proceeds and the amount of expenses pertaining to a specified sale of assets falling under a long-term installment sale, etc. of a corporation that is subject to the provisions of the main clause of Article 63, paragraph (1) of the Former Corporation Tax Act Kept in Force fall under the cases set forth in the items of the preceding paragraph, and the unrecognized revenue pertaining to that specified sale of assets exceeds the unrecognized expenses pertaining to that specified sale of assets, notwithstanding the provisions of that paragraph, the amount set forth in item (i) (for a business year containing the date of dissolution or of discontinuance or transfer of the whole of the business (excluding a transfer to a succeeding corporation in a company split through a qualified company split and any other transfer specified by Cabinet Order), a business year during liquidation or a business year containing the day preceding the date of the merger of an acquired corporation (excluding a qualified merger), a business year containing the day preceding the day on which an ordinary corporation or a cooperative, etc. comes to fall under a public interest corporation, etc. in the case where it so comes to fall, and a business year in which the amount set forth in that item exceeds the amount set forth in item (ii), the amount set forth in item (ii)) is included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for each business year on or after the base business year:

④The provisions of the preceding paragraph apply only if the Final Return for the base business year (in the case of filing an interim return for the base business year containing the matters set forth in the items of Article 72, paragraph (1) or the items of Article 144-4, paragraph (1) or (2) of the Corporation Tax Act, that interim return; the same applies in the following paragraph) contains a statement of the amounts to be included in the amount of gross profit and the amount of deductible expenses pursuant to the provisions of the preceding paragraph.

⑤Even in the case where a Final Return without entries for the matters set forth in the preceding paragraph has been filed, the district director may apply the provisions of paragraph (3), when they find any unavoidable grounds for the person's failure to make entries for such matters.

⑥The number of months referred to in paragraph (3), item (i) is calculated in accordance with the calendar, and any fraction of less than one month is rounded down.

⑦If a domestic corporation prescribed in Article 64-11, paragraph (1) of the Corporation Tax Act, another domestic corporation prescribed in Article 64-12, paragraph (1) of that Act or a group tax sharing corporation prescribed in Article 64-13, paragraph (1) of that Act (limited to one that falls under the requirement set forth in item (i) of that paragraph) is subject to the provisions of Article 63, paragraph (1) of the Former Corporation Tax Act Kept in Force in a business year of fair valuation (meaning the business year immediately before the start of group tax sharing prescribed in Article 64-11, paragraph (1) of that Act, the business year immediately before joining group tax sharing prescribed in Article 64-12, paragraph (1) of that Act or the business year immediately before the end of group tax sharing prescribed in Article 64-13, paragraph (1) of that Act (excluding any of those business years that is subject to the provisions of Article 63, paragraph (4) of the Former Corporation Tax Act Kept in Force); the same applies hereinafter in this paragraph), the amount of proceeds and the amount of expenses pertaining to the specified sale of assets subject to those provisions (excluding those included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income or the amount of consolidated income for each business year or each consolidated business year before that business year of fair valuation, and those included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for that business year of fair valuation pursuant to the provisions of that paragraph) are included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for that business year of fair valuation, except for those pertaining to a contract that meets the requirements specified by Cabinet Order as a contract under which the difference between that amount of proceeds and that amount of expenses is small, or to any other contract specified by Cabinet Order.

⑧Special provisions for the treatment of the amount of proceeds and the amount of expenses pertaining to a specified sale of assets in the case where a contract pertaining to that specified sale of assets falling under a long-term installment sale, etc. has been transferred through a qualified merger, qualified company split, qualified capital contribution in kind or qualified in-kind distribution, and other necessary matters concerning the application of the provisions of paragraphs (1) through (3) and the preceding paragraph are specified by Cabinet Order.

The provisions of Article 69, paragraph (7) of the New Corporation Tax Act apply to corporation tax on income for business years of domestic corporations that begin on or after January 1, 2019, and with regard to corporation tax on income for business years of domestic corporations that began before that date, the provisions then in force continue to govern.

The provisions of Article 69-2 of the New Corporation Tax Act apply to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in paragraph (1) of that Article that pertains to distributions of proceeds from group investment trusts that a domestic corporation receives on or after January 1, 2020.

The provisions of Part II, Chapter I, Section 3, Subsection 2-2 of the New Corporation Tax Act apply to corporation tax on income for business years of domestic corporations that begin on or after April 1, 2020.

①With regard to the calculation of the amount of consolidated income for a consolidated business year (limited to a consolidated business year that begins on or before March 31, 2030) of a consolidated corporation that ends on or after the Effective Date, in Article 81-3, paragraph (1) of the New Corporation Tax Act, the phrase "(Calculation of the Amount of Income for Each Business Year)" is deemed to be replaced with "(Calculation of the Amount of Income for Each Business Year) and the provisions of Article 53 (Returned Goods Adjustment Reserves) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 7 of 2018), which remain in force pursuant to the provisions of Article 25, paragraph (1) (Transitional Measures Concerning Returned Goods Adjustment Reserves of Corporations) of the Supplementary Provisions of that Act".

②The amount that would be the amount of gross profit if the amount of income for the business year were calculated pursuant to the provisions of Article 25, paragraphs (2) through (4) of the Supplementary Provisions by deeming the period of a consolidated business year of a consolidated corporation to be a business year referred to in Article 22, paragraph (1) of the New Corporation Tax Act is to be included in the individual amount of gross profit prescribed in Article 81-3, paragraph (1) of the New Corporation Tax Act.

①With regard to the calculation of the amount of consolidated income for a consolidated business year (limited to a consolidated business year that begins on or before March 31, 2023) of a consolidated corporation that ends on or after the Effective Date, in Article 81-3, paragraph (1) of the New Corporation Tax Act, the phrase "(Calculation of the Amount of Income for Each Business Year)" is deemed to be replaced with "(Calculation of the Amount of Income for Each Business Year) and the provisions of Article 63 (Business Year for Vesting Proceeds and Expenses Pertaining to Long-Term Installment Sales, etc.) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 7 of 2018), which remain in force pursuant to the provisions of Article 28, paragraph (1) (Transitional Measures Concerning the Business Year for Vesting Proceeds and Expenses Pertaining to Long-Term Installment Sales, etc.) of the Supplementary Provisions of that Act".

②The amount that would be the amount of gross profit or the amount of deductible expenses if the amount of income for the business year were calculated pursuant to the provisions of Article 28, paragraph (2) or (3) of the Supplementary Provisions by deeming the period of a consolidated business year of a consolidated corporation to be a business year referred to in Article 22, paragraph (1) of the New Corporation Tax Act is to be included in the individual amount of gross profit or the individual amount of deductible expenses prescribed in Article 81-3, paragraph (1) of the New Corporation Tax Act.

The provisions of Article 81-8-2 of the New Corporation Tax Act apply to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in Article 81-15-2, paragraph (1) of the New Corporation Tax Act that pertains to the amount of income tax on distributions of proceeds from group investment trusts that a consolidated corporation receives on or after January 1, 2020.

The provisions of Article 81-15-2 of the New Corporation Tax Act apply to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in paragraph (1) of that Article that pertains to distributions of proceeds from group investment trusts that a consolidated corporation receives on or after January 1, 2020.

The provisions of Part II, Chapter I-2, Section 3, Subsection 2-2 of the New Corporation Tax Act apply to corporation tax on consolidated income for consolidated business years of consolidated parent corporations that begin on or after April 1, 2020.

①The provisions of Article 81-25, paragraph (2) of the New Corporation Tax Act apply to documents stating the individually attributed amounts, etc. prescribed in paragraph (1) of that Article for consolidated business years that end on or after April 1, 2020.

②The provisions of Article 81-25, paragraphs (3) and (4) of the New Corporation Tax Act apply to the documents prescribed in paragraph (3) of that Article that pertain to a change in the individually attributed amounts, etc. prescribed in paragraph (1) of that Article in the case where the change occurs on or after April 1, 2020, and with regard to the documents prescribed in paragraph (2) of that Article that pertain to a change in the individually attributed amounts, etc. prescribed in Article 81-25, paragraph (1) of the Former Corporation Tax Act in the case where the change occurred before that date, the provisions then in force continue to govern.

The provisions of Article 139, paragraph (2) of the New Corporation Tax Act apply to corporation tax on income for business years of foreign corporations that begin on or after January 1, 2019, and with regard to corporation tax on income for business years of foreign corporations that began before that date, the provisions then in force continue to govern.

The provisions of Article 142-6-2 of the New Corporation Tax Act apply to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in Article 144-2-2, paragraph (1) of the New Corporation Tax Act that pertains to the amount of income tax on distributions of proceeds from group investment trusts that a foreign corporation that has a permanent establishment receives on or after January 1, 2020.

The provisions of Article 144-2-2 of the New Corporation Tax Act apply to the amount equivalent to foreign tax adjusted at the time of distribution prescribed in paragraph (1) of that Article that pertains to distributions of proceeds from group investment trusts that a foreign corporation that has a permanent establishment receives on or after January 1, 2020.

①The provisions of Article 151 of the New Corporation Tax Act apply to Final Returns for business years of foreign corporations that end on or after the Effective Date, to interim returns for corporation tax of foreign corporations for which the tax liability pertaining to the interim return arises on or after the Effective Date, and to amended returns pertaining to Final Returns and interim returns of foreign corporations, that foreign corporations file on or after the Effective Date.

②With regard to the autographs and seals under the provisions of Article 151, paragraphs (1) through (4) of the Former Corporation Tax Act for Final Returns for business years of corporations that ended before the Effective Date (excluding those filed on or after April 1, 2021), interim returns for corporation tax of corporations for which the tax liability pertaining to the interim return arose before the Effective Date, consolidated Final Returns for consolidated business years of consolidated corporations that ended before the Effective Date (excluding those filed on or after April 1, 2021) and consolidated interim returns for corporation tax of consolidated corporations for which the tax liability pertaining to the consolidated interim return arose before the Effective Date, and amended returns pertaining to these returns, that corporations filed before the Effective Date, and for the documents prescribed in Article 81-25, paragraph (1) of the Former Corporation Tax Act stating the individually attributed amounts, etc. prescribed in that paragraph for consolidated business years of consolidated corporations that ended before the Effective Date (including the documents prescribed in paragraph (2) of that Article that pertain to a change in the individually attributed amounts, etc. prescribed in paragraph (1) of that Article in the case where the change occurred before the Effective Date, and excluding those filed on or after April 1, 2021), 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.

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.