①In the case where a corporation enters into a contract for the transfer of crypto-assets (meaning crypto-assets prescribed in Article 2, paragraph (5) of the Payment Services Act (Act No. 59 of 2009); the same applies hereinafter in this Article) in a business year before the business year of the amendment (meaning the business year that first ends on or after the Effective Date; the same applies hereinafter in this paragraph) and delivers those crypto-assets in a business year on or after the business year of the amendment, the amount of profit from the transfer or the amount of loss from the transfer prescribed in Article 61, paragraph (1) of the Corporation Tax Act pertaining to that transfer is, notwithstanding the provisions of that paragraph, included in the amount of gross profit or the amount of deductible expenses for the business year containing the date of that delivery; provided, however, that this does not apply to a transfer for which the corporation entered into the contract in a business year before the business year of the amendment and included the amount equivalent to the amount of profit from the transfer or the amount of loss from the transfer prescribed in that paragraph pertaining to that transfer in the amount of gross profit or the amount of deductible expenses for the business year containing the date on which it entered into that contract.

②The provisions of Article 61, paragraph (4) of the New Corporation Tax Act (limited to the portion pertaining to virtual currencies) apply to qualified company splits, etc. prescribed in that paragraph (referred to as "qualified company splits, etc." in the following paragraph) that a corporation carries out on or after the Effective Date.

③In the case where, among the crypto-assets falling under short-term trading commodities, etc. prescribed in Article 61, paragraph (2) of the Corporation Tax Act that a corporation holds, there are those that it holds at the end of a business year that begins before the Effective Date and ends on or after the Effective Date (hereinafter referred to as a "transitional business year" in this paragraph and paragraph (5)), or those transferred to a succeeding corporation in a company split, a corporation receiving a capital contribution in kind or a corporation receiving a distribution in kind through a qualified company split, etc. carried out within the period of the transitional business year on or after the Effective Date, when, for none of those crypto-assets, the corporation has booked the valuation gain or valuation loss prescribed in Article 61, paragraph (3) of that Act as proceeds or a loss in the final settlement of accounts for that transitional business year (in the case of filing an interim return 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 that Act for the period prescribed in Article 72, paragraph (1) or Article 144-4, paragraph (1) or (2) of that Act, the settlement of accounts for that period; the same applies in paragraph (5)) (for crypto-assets transferred through that qualified company split, etc., when it has not treated the amount equivalent to the valuation gain or valuation loss prescribed in paragraph (4) of that Article as an amount of proceeds or an amount of loss), the corporation may, for that transitional business year, apply the provisions of that Article and Articles 61-6 and 61-8 of that Act by deeming the crypto-assets falling under short-term trading commodities, etc. prescribed in paragraph (2) of that Article that it holds not to fall under short-term trading commodities, etc. prescribed in that paragraph.

④The provisions of Article 61, paragraph (8) of the New Corporation Tax Act apply to qualified company splits, etc. prescribed in that paragraph (referred to as "qualified company splits, etc." in the following paragraph) that a corporation carries out on or after the Effective Date.

⑤In the case where, among the crypto-asset margin transactions prescribed in Article 61, paragraph (7) of the Corporation Tax Act (hereinafter referred to as "crypto-asset margin transactions" in this paragraph) that a corporation has carried out, there are those that have not been settled at the end of the transitional business year, or those whose contracts have been transferred to a succeeding corporation in a company split or a corporation receiving a capital contribution in kind through a qualified company split, etc. carried out within the period of the transitional business year on or after the Effective Date, when, for none of those transactions, the corporation has booked the amount of deemed settlement gain or loss prescribed in paragraph (7) of that Article as proceeds or a loss in the final settlement of accounts for that transitional business year (for crypto-asset margin transactions pertaining to contracts transferred through that qualified company split, etc., when it has not treated the amount equivalent to the amount of deemed settlement gain or loss prescribed in paragraph (8) of that Article as an amount of proceeds or an amount of loss), the corporation may choose not to apply the provisions of paragraphs (7) through (9) of that Article for that transitional business year.