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.