This Act comes into effect on April 1, 2020; provided, however, that the provisions set forth in the following items come into effect as of the days specified in those items.

①Unless otherwise provided for, the provisions of the Corporation Tax Act as amended by the provisions of Article 3 (limited to the amending provisions set forth in Article 1, item (v), (b) of the Supplementary Provisions; the same applies hereinafter in this paragraph) (hereinafter referred to as "the New Corporation Tax Act"), the Local Corporation Tax Act as amended by the provisions of Article 4 (limited to the amending provisions set forth in (c) of that item; the same applies in the following paragraph) (hereinafter referred to as "the New Local Corporation Tax Law"), the Act on General Rules for National Taxes as amended by the provisions of Article 13 (limited to the amending provisions set forth in (f) of that item; the same applies in the following paragraph), the National Tax Collection Act as amended by the provisions of Article 14 (limited to the amending provisions set forth in (g) of that item; the same applies in the following paragraph), the Act on Special Measures Concerning Taxation as amended by the provisions of Article 16 (hereinafter referred to as the "Act on Special Measures Concerning Taxation as Amended for 2022"), the Act on Special Provisions concerning Preservation Methods for Books and Documents Related to National Tax Prepared by Means of Computers as amended by the provisions of Article 21, the Act on Temporary Special Provisions of the Acts on National Taxes for Victims, etc. of the Great East Japan Earthquake as amended by the provisions of Article 23 (hereinafter referred to as the "Earthquake Tax Special Provisions Law as Amended for 2022") and the Act Partially Amending the Income Tax Act, etc. as amended by the provisions of Article 30 (limited to the amending provisions set forth in (t) of that item; the same applies in the following paragraph) apply to corporation tax on income for business years of corporations (including associations or foundations without juridical personality; the same applies in the following paragraph and Article 22 of the Supplementary Provisions) that begin on or after April 1, 2022 (excluding business years of a consolidated subsidiary corporation prescribed in Article 2, item (xii)-7 of the Corporation Tax Act prior to the amendment by the provisions of Article 3 (hereinafter referred to as "the Former Corporation Tax Act") (hereinafter referred to as a "consolidated subsidiary corporation" through Article 32 of the Supplementary Provisions) whose consolidated parent corporation business year (meaning a consolidated parent corporation business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act; the same applies hereinafter through Article 32 of the Supplementary Provisions) began before that date (hereinafter referred to as a "former business year" in this Article)) and to local corporation tax on the base corporation tax amount for taxable business years that begin on or after that date (excluding former business years).

②Unless otherwise provided for, with regard to corporation tax on income for business years of corporations that began before April 1, 2022 (including former business years), corporation tax on consolidated income (meaning consolidated income prescribed in Article 2, item (xviii)-4 of the Former Corporation Tax Act; the same applies hereinafter through Article 35 of the Supplementary Provisions) for consolidated business years (meaning consolidated business years prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act; the same applies hereinafter through Article 37 of the Supplementary Provisions) of consolidated corporations (meaning consolidated corporations prescribed in Article 2, item (xii)-7-2 of the Former Corporation Tax Act; the same applies hereinafter through Article 35 of the Supplementary Provisions) whose consolidated parent corporation business year began before that date, and local corporation tax on the base corporation tax amount for taxable business years of corporations that began before that date (including former business years), the provisions of the Former Corporation Tax Act, the Local Corporation Tax Act prior to the amendment by the provisions of Article 4 (hereinafter referred to as "the Former Local Corporation Tax Law"), the Act on General Rules for National Taxes prior to the amendment by the provisions of Article 13, the National Tax Collection Act prior to the amendment by the provisions of Article 14, the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 16 (hereinafter referred to as the "Act on Special Measures Concerning Taxation Before the 2022 Changes"), the Act on Exemption, etc. of Income Tax, etc. on Income of Foreign Residents, etc. Based on the Principle of Reciprocity prior to the amendment by the provisions of Article 17 (limited to the amending provisions set forth in Article 1, item (v), (j) of the Supplementary Provisions), the Act on Special Provisions of the Income Tax Act, the Corporation Tax Act and the Local Tax Act Incidental to Enforcement of Tax Treaties, etc. prior to the amendment by the provisions of Article 18 (limited to the amending provisions set forth in (k) of that item), the Act on Special Provisions concerning Preservation Methods for Books and Documents Related to National Tax Prepared by Means of Computers prior to the amendment by the provisions of Article 21, the Act on Temporary Special Provisions of the Acts on National Taxes for Victims, etc. of the Great East Japan Earthquake prior to the amendment by the provisions of Article 23 (hereinafter referred to as the "Earthquake Tax Special Provisions Law Before the 2022 Changes") and the Act Partially Amending the Income Tax Act, etc. prior to the amendment by the provisions of Article 30 remain in force.

①An application referred to in Article 4-3, paragraph (1) of the Former Corporation Tax Act that was made before April 1, 2022, for which neither the approval referred to in Article 4-2 of the Former Corporation Tax Act nor the disposition denying the application referred to in Article 4-3, paragraph (2) of the Former Corporation Tax Act has been made at the time this Act (limited to the amending provisions set forth in Article 1, item (v) of the Supplementary Provisions) comes into effect, is deemed to be an application referred to in Article 64-9, paragraph (2) of the New Corporation Tax Act, except in the case where the provisions of the following paragraph apply.

②With regard to the approval referred to in Article 4-2 of the Former Corporation Tax Act for a domestic corporation referred to in Article 4-3, paragraph (6) of the Former Corporation Tax Act and another domestic corporation referred to in paragraph (8) of that Article (limited to a corporation set forth in paragraph (9), item (ii) of that Article) in the case where the special consolidated application year prescribed in paragraph (6) of that Article of that domestic corporation is a business year that began before April 1, 2022, for another domestic corporation referred to in paragraph (10) of that Article in the case where the day on which that other domestic corporation came to have the full controlling interest prescribed in that paragraph is a day within the period of a consolidated parent corporation business year that began before April 1, 2022, and for another domestic corporation referred to in paragraph (11) of that Article (limited to a corporation set forth in item (ii) of that paragraph) in the case where the day specified in that item for that other domestic corporation is a day within the period of a special consolidated application year prescribed in paragraph (6) of that Article that began before April 1, 2022, the provisions then in force continue to govern. In this case, the business year of those other domestic corporations containing the day preceding the day on which that approval takes effect (limited to a business year that begins on or after April 1, 2022) is deemed to be a former business year prescribed in paragraph (1) of the preceding Article, and the provisions of Article 61-12 of the Former Corporation Tax Act and other provisions specified by Cabinet Order apply.

①With regard to the rescission of the approval referred to in Article 4-2 of the Former Corporation Tax Act for a consolidated corporation whose consolidated parent corporation business year that began before April 1, 2022 has not ended, in the case where any of the facts set forth in the items of Article 4-5, paragraph (1) of the Former Corporation Tax Act exists with regard to that consolidated corporation, the provisions then in force continue to govern.

②With regard to the rescission of the approval referred to in Article 4-2 of the Former Corporation Tax Act in the case where any of the following facts has occurred, the provisions then in force continue to govern:

③With regard to the approval referred to in Article 4-5, paragraph (3) of the Former Corporation Tax Act for a consolidated corporation whose consolidated parent corporation business year that began before April 1, 2022 has not ended, the provisions then in force continue to govern.

①The provisions of Article 14, paragraph (1) of the New Corporation Tax Act (limited to the portion pertaining to items (i), (ii), (v) and (vi)) apply to the business years of the corporations referred to in that paragraph in the case where the day specified in those items is a day within the period of a business year that begins on or after April 1, 2022 (for a consolidated subsidiary corporation, excluding the period of a consolidated parent corporation business year that began before that date).

②With regard to the business years of the corporations referred to in Article 14, paragraph (1) of the Former Corporation Tax Act in the case where the day specified in the following items according to the category of facts set forth in the respective items is a day within the period of a business year that began before April 1, 2022 (for a consolidated subsidiary corporation, including the period of a consolidated parent corporation business year that began before that date), the provisions then in force continue to govern:

③The provisions of Article 14, paragraph (2) of the New Corporation Tax Act apply to a business year of a domestic corporation set forth in Article 14, paragraph (2) of the New Corporation Tax Act whose approval under Article 64-9, paragraph (1) of the New Corporation Tax Act ceases to be effective on or after April 1, 2022.

④The provisions of Article 14, paragraph (3) of the New Corporation Tax Act apply to a business year of a group tax sharing subsidiary corporation that has a group tax sharing full controlling interest with a group tax sharing parent corporation at the start or at the end of a business year of the group tax sharing parent corporation that begins on or after April 1, 2022.

⑤The provisions of Article 14, paragraphs (4) through (6) and paragraph (8) of the New Corporation Tax Act apply to a business year of a domestic corporation set forth in paragraph (4) of that Article or of a domestic corporation listed in any of the items of paragraph (5) of that Article, in the case where the day specified in any of the items of paragraph (4) or any of the items of paragraph (5) of that Article is a day within the period of a business year of the group tax sharing parent corporation or of the parent corporation prescribed in item (i) of that paragraph that begins on or after April 1, 2022.

⑥The provisions of Article 14, paragraph (7) of the New Corporation Tax Act apply to a period prescribed in that paragraph that begins on or after April 1, 2022.

With regard to the application of the provisions of Article 26, paragraph (3) of the New Corporation Tax Act, the applicable business year prescribed in that paragraph is to include a consolidated business year for which the provisions of Article 81-15, paragraphs (1) through (3) of the Former Corporation Tax Act were applied.

The provisions of Article 54, paragraph (1) of the Corporation Tax Act as amended by Article 3 apply to specified restricted shares prescribed in that paragraph for which a corporation makes a resolution on their delivery (or, if no such resolution is made, delivers them) on or after the date specified in Article 1, item (vii) of the Supplementary Provisions, and to succeeding restricted shares prescribed in that paragraph pertaining to those specified restricted shares; with regard to specified restricted shares prescribed in Article 54, paragraph (1) of the Corporation Tax Act prior to the amendment by Article 3 for which a corporation made a resolution on their delivery (or, if no such resolution was made, delivered them) before that date, and to succeeding restricted shares prescribed in that paragraph pertaining to those specified restricted shares, the provisions then in force continue to govern.

①In the case where the approval under Article 4-2 of the Former Corporation Tax Act of a domestic corporation has been revoked pursuant to the provisions of Article 4-5, paragraph (2) of the Former Corporation Tax Act (including the case where the approval under Article 4-2 of the Former Corporation Tax Act has been revoked as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (2) of the Supplementary Provisions; referred to as the "case of revocation of approval" in this paragraph), where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions; referred to as the "case of approval of withdrawal" in this paragraph), or where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to it (referred to as the "case where consolidated tax payment ends" in this paragraph), if there is any individually attributed consolidated deficit of the domestic corporation (meaning an individually attributed consolidated deficit prescribed in Article 81-9, paragraph (6) of the Former Corporation Tax Act; the same applies in this Article and the following Article) that arose in any consolidated business year that began within ten years before the first day of the business year that includes the day following the last day of the final consolidated business year in that case of revocation of approval, that case of approval of withdrawal or that case where consolidated tax payment ends, then, with regard to the application of the provisions of Article 57, paragraph (1) of the New Corporation Tax Act, that individually attributed consolidated deficit is deemed to be a net operating loss that arose in the business year of the domestic corporation that includes the first day of the consolidated business year in which that individually attributed consolidated deficit arose (or, if the provisions of Article 29, paragraph (1) of the Supplementary Provisions have been applied, the last day of that consolidated business year).

②In the case where the acquired corporation in a qualified merger set forth in Article 57, paragraph (2) of the New Corporation Tax Act is a consolidated corporation (limited, in the case of a consolidated subsidiary corporation, to one that carries out, on the day following the last day of a consolidated business year, a qualified merger in which that consolidated subsidiary corporation is the acquired corporation), or where the other domestic corporation for which the determination of residual assets set forth in that paragraph has been made is a consolidated corporation (limited to a consolidated subsidiary corporation for which the determination of residual assets was made on the last day of a consolidated business year of that consolidated corporation), the provisions of Article 57, paragraphs (2) and (3) of the New Corporation Tax Act apply by deeming the individually attributed consolidated deficit that arose in each consolidated business year of the acquired corporation or the other domestic corporation that began within 10 years before the day of that qualified merger, or that began within 10 years before the day following the day of that determination of residual assets, to be a net operating loss that arose in a business year within the preceding 10 years prescribed in that paragraph, by deeming a consolidated tax return (meaning a consolidated tax return prescribed in Article 2, item (xxxii) of the Former Corporation Tax Act; the same applies in Article 33 and Article 35, paragraph (2) of the Supplementary Provisions) to be a Final Return that is a Blue Return, and by deeming the consolidated business year in which that individually attributed consolidated deficit arose to be a business year of the acquired corporation or the other domestic corporation.

③In the case prescribed in the preceding paragraph, when a consolidated corporation that becomes an acquired corporation involved in a qualified merger set forth in the paragraph or another domestic corporation whose residual assets have been determined shows any net operating loss that arose in each business year prior to each consolidated business year, as prescribed in the paragraph, that falls under a business year within preceding ten years as prescribed in Article 57, paragraph (2) of the New Corporation Tax Act, the provisions of the paragraph do not apply to the net operating loss.

④With regard to the application of the provisions of Article 57, paragraph (1) of the New Corporation Tax Act in each business year after the final consolidated business year in the case where a domestic corporation set forth in Article 57, paragraph (1) of the New Corporation Tax Act, after the last day of the first consolidated business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act, has had the approval under Article 4-2 of the Former Corporation Tax Act revoked pursuant to the provisions of Article 4-5, paragraph (1) or (2) of the Former Corporation Tax Act (including the case where it has had the approval under Article 4-2 of the Former Corporation Tax Act revoked as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (1) or (2) of the Supplementary Provisions), has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions), or has had the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions applied, the net operating losses that arose in each business year prior to that consolidated business year (including those deemed, in each such business year, to be net operating losses that arose in a business year prior to each such business year pursuant to the provisions of Article 57, paragraph (2) or (6) of the Former Corporation Tax Act) are deemed not to exist.

⑤With regard to the application of the provisions of Article 57 of the New Corporation Tax Act in the case where the provisions of paragraph (1) or the preceding paragraph apply, the phrase "of this paragraph" in paragraph (2) of that Article is deemed to be replaced with "of this paragraph or Article 20, paragraph (1) (Transitional Measures for Carryover of Losses) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Income Tax Act Amendment' in this Article)", the phrase "第九項又は" (paragraph 9 or) with "第九項若しくは" (paragraph 9 or, joining a smaller group of alternatives), and the phrase "Article 58, paragraph (1) (Special Provisions for Losses in Business Years for Which No Blue Return Was Filed)" with "Article 58, paragraph (1) (Special Provisions for Losses in Business Years for Which No Blue Return Was Filed) or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "(including those deemed to be net operating losses of the domestic corporation pursuant to the provisions of paragraph (2)" in paragraph (4) of that Article is deemed to be replaced with "(including those deemed to be net operating losses of the domestic corporation pursuant to the provisions of paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", and the phrase "or Article 58, paragraph (1)" with "or Article 58, paragraph (1), or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "paragraph (2)" in paragraph (6) and paragraph (7), item (i) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "paragraph (2)" in paragraph (8), item (i) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", and the phrase "or Article 58, paragraph (1)" with "or Article 58, paragraph (1), or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; and the phrase "paragraph (2)" in paragraph (9) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment".

⑥The provisions of paragraph (1) of Article 57 of the New Corporation Tax Act concerning an amount deemed to be a net operating loss of a domestic corporation pursuant to the provisions of paragraph (1), or an amount deemed to be a net operating loss of a domestic corporation pursuant to the provisions of Article 57, paragraph (2) of the New Corporation Tax Act as applied with the deeming under paragraph (2), apply only in the case where that domestic corporation has filed a Final Return for the business year that includes the day following the last day of the final consolidated business year set forth in paragraph (1), or for the business year of the merger, etc. prescribed in paragraph (2) of that Article as applied with the deeming under paragraph (2), and has subsequently filed Final Returns continuously, and where it keeps the books and documents pertaining to the business year in which the amount deemed to be a net operating loss arose as specified by Ministry of Finance Order prescribed in Article 57, paragraph (10) of the Former Corporation Tax Act.

⑦In the case where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to a domestic corporation, if there is any individually attributed consolidated deficit of the domestic corporation that arose in any consolidated business year that began within nine years before the first day of the business year that includes the day following the last day of the final consolidated business year (limited to a consolidated business year that began before April 1, 2018), then, with regard to the application of the provisions of Article 57, paragraph (1) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 9 of 2015) (referred to as the "2015 Former Corporation Tax Act" in the provisions up to Article 22 of the Supplementary Provisions) in the case where the provisions then in force continue to govern pursuant to the provisions of Article 27, paragraph (1) of the Supplementary Provisions of that Act, that individually attributed consolidated deficit is deemed to be a net operating loss that arose in the business year of the domestic corporation that includes the last day of the consolidated business year in which that individually attributed consolidated deficit arose (or, if the provisions of Article 29, paragraph (2) of the Supplementary Provisions have been applied, the first day of that consolidated business year).

⑧With regard to the application of the provisions of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act in each business year after the final consolidated business year in the case where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to a domestic corporation, the net operating losses that arose in each business year prior to that consolidated business year (including those deemed, in each such business year, to be net operating losses that arose in a business year prior to each such business year pursuant to the provisions of Article 57, paragraph (2) or (6) of the 2015 Former Corporation Tax Act) are deemed not to exist.

⑨With regard to the application of the provisions of Article 57, paragraphs (2) through (4), paragraph (8) and paragraph (10) of the 2015 Former Corporation Tax Act in the case where the provisions of the preceding two paragraphs apply, an amount deemed to be a net operating loss of the domestic corporation set forth in paragraph (7) pursuant to the provisions of that paragraph is deemed to be an amount deemed to be a net operating loss of that domestic corporation pursuant to the provisions of paragraph (6) of that Article, and a net operating loss deemed not to exist pursuant to the provisions of the preceding paragraph is deemed to be a net operating loss deemed not to exist pursuant to the provisions of paragraph (9) of that Article, respectively.

⑩With regard to the application of the provisions of Article 57, paragraphs (6) through (9) of the New Corporation Tax Act to a net operating loss that arose in a business year that began before April 1, 2018, the phrase "of paragraph (1)" in paragraph (6) of that Article is deemed to be replaced with "of Article 57, paragraph (1) (Carryover of Losses in a Business Year When a Blue Return Has Been Filed) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 9 of 2015) (referred to as the '2015 Former Corporation Tax Act' in this Article) in the case where the provisions then in force continue to govern pursuant to the provisions of Article 27, paragraph (1) (Transitional Measures for Carryover of Losses in Business Years When a Blue Return Has Been Filed, etc.) of the Supplementary Provisions of that Act", and the phrase "paragraph (2)" with "paragraph (2) or (6) of that Article or Article 20, paragraph (7) (Transitional Measures for Carryover of Losses) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Income Tax Act Amendment' in this Article)"; the phrase ", paragraph (2)" in paragraph (7) of that Article is deemed to be replaced with ", Article 57, paragraph (2) of the 2015 Former Corporation Tax Act"; the phrase "business year within preceding ten years" in item (i) of that paragraph is deemed to be replaced with "business year within preceding nine years prescribed in Article 57, paragraph (2) of the 2015 Former Corporation Tax Act", and the phrase "paragraph (2)" with "that paragraph or paragraph (6) of that Article or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "of paragraph (1) in each business year" in paragraph (8) of that Article is deemed to be replaced with "of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act in each business year"; the phrase "business years within ten years before group tax sharing" in item (i) of that paragraph is deemed to be replaced with "business years within nine years before group tax sharing", the phrase "within ten years" with "within nine years", the phrase "paragraph (2)" with "Article 57, paragraph (2) or (6) of the 2015 Former Corporation Tax Act or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", the phrase ", paragraph (1)" with ", Article 57, paragraph (1) of the 2015 Former Corporation Tax Act", the phrase "paragraphs (4) through (6)" with "the provisions of paragraph (4), (5) or (9) of that Article, paragraph (6)", and the phrase "or Article 58, paragraph (1)" with "or the provisions of Article 20, paragraph (8) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "business years within ten years before group tax sharing" in item (ii) of that paragraph is deemed to be replaced with "business years within nine years before group tax sharing"; and the phrase "paragraph (1)" in paragraph (9) of that Article is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act", and the phrase "paragraph (2)" with "paragraph (2) or (6) of that Article or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment".

⑪The provisions of Article 57, paragraph (6), paragraph (7) (limited to the part pertaining to item (i)) and paragraph (8) of the New Corporation Tax Act do not apply to the net operating loss of a group tax sharing corporation that is deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions.

⑫The provisions of Article 57, paragraphs (6) through (8) of the New Corporation Tax Act apply by deeming a domestic corporation that is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and by deeming a domestic corporation that is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively.

⑬With regard to the application of the provisions of Article 57 of the New Corporation Tax Act to a group tax sharing parent corporation and the other group tax sharing corporations in the case where the group tax sharing parent corporation is one deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, and a fact listed in Article 57, paragraph (11), item (ii), (a) through (d) of the Former Corporation Tax Act occurred with respect to that group tax sharing parent corporation in a business year that began before April 1, 2022, the phrase "with respect to a domestic corporation" in paragraph (11), item (ii) of that Article is deemed to be replaced with "with respect to a domestic corporation (including the group tax sharing parent corporation related to that domestic corporation)", and the phrase "of that domestic corporation" with "of the domestic corporation with respect to which that fact occurred".

⑭Necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.

①With regard to the application of the provisions of Article 57-2 of the New Corporation Tax Act, the net operating loss prescribed in paragraph (1) of that Article is to include amounts deemed to be net operating losses pursuant to the provisions of paragraph (1) or (7) of the preceding Article (limited to those to which the provisions of Article 57, paragraph (1) of the New Corporation Tax Act or Article 57, paragraph (1) of the 2015 Former Corporation Tax Act apply).

②A domestic corporation that, as of the last day of the final consolidated business year in which it was subject to corporation tax on consolidated income for each consolidated business year, was a consolidated corporation showing a loss, etc. prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act (referred to as a "consolidated corporation showing a loss, etc." in this Article) is deemed to be a corporation showing a loss, etc. prescribed in Article 57-2, paragraph (1) of the New Corporation Tax Act (referred to as a "corporation showing a loss, etc." in this Article), and the provisions of Article 57-2 of the New Corporation Tax Act apply. In this case, the day specified by Cabinet Order prescribed in Article 57-2, paragraph (1) of the Former Corporation Tax Act is deemed to be the date of control prescribed in Article 57-2, paragraph (1) of the New Corporation Tax Act.

③In the case where, on or after the relevant day prescribed in Article 57-2, paragraph (1) of the New Corporation Tax Act of a corporation showing a loss, etc. (including one deemed to be a corporation showing a loss, etc. pursuant to the provisions of the preceding paragraph; the same applies in this paragraph and paragraph (5)) (including the relevant day prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act), a qualified merger in which the corporation showing a loss, etc. is the acquiring corporation is carried out between the corporation showing a loss, etc. and another corporation, the provisions of paragraph (2) of the preceding Article do not apply to the individually attributed consolidated deficit that arose in each consolidated business year of the acquired corporation in the qualified merger up to and including the consolidated business year that includes the day before the day of the qualified merger (or, if the qualified merger is carried out after the day on which three years have elapsed from the first day of the applicable consolidated business year (meaning the applicable consolidated business year prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act; the same applies in this Article) of the corporation showing a loss, etc. (or, if the day on which those years have elapsed falls after the day on which five years have elapsed from the specified date of control prescribed in Article 57-2, paragraph (1) of the Former Corporation Tax Act, that day on which five years have elapsed; referred to as the "day on which three years have elapsed" in paragraph (5)), limited to, of that individually attributed consolidated deficit, the portion for which the first day of the consolidated business year in which it arose is before the first day of that applicable consolidated business year).

④With regard to the application of the provisions of Article 57-2, paragraph (2) of the New Corporation Tax Act, the relevant day prescribed in that paragraph is to include the relevant day prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act.

⑤In the case where, on or after the relevant day prescribed in Article 57-2, paragraph (1) of the New Corporation Tax Act of a corporation showing a loss, etc., the determination of residual assets is made for a domestic corporation that has a full controlling interest prescribed in Article 57, paragraph (2) of the New Corporation Tax Act with the corporation showing a loss, etc. and of which the corporation showing a loss, etc. holds all or part of the issued shares or capital contributions, the provisions of paragraph (2) of the preceding Article do not apply, with respect to the corporation showing a loss, etc., to the individually attributed consolidated deficit that arose in each consolidated business year of that domestic corporation up to and including the consolidated business year that includes the day of that determination of residual assets (or, if the day of that determination of residual assets is on or after the day on which three years have elapsed for the corporation showing a loss, etc., limited to, of that individually attributed consolidated deficit, the portion for which the first day of the consolidated business year in which it arose is before the first day of the applicable consolidated business year of the corporation showing a loss, etc.).

⑥In the case where a consolidated corporation showing a loss, etc., on or after the relevant day prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act, falls under the case of revocation of approval or the case of approval of withdrawal prescribed in paragraph (1) of the preceding Article, or has had the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions applied, the provisions of paragraphs (1) and (7) of the preceding Article do not apply to the individually attributed consolidated deficit that arose in each consolidated business year prior to the applicable consolidated business year of the consolidated corporation showing a loss, etc.

⑦In the case where a qualified merger in which a domestic corporation is the acquiring corporation is carried out between the domestic corporation and a consolidated corporation showing a loss, etc., or where the residual assets of a consolidated corporation showing a loss, etc. that is another domestic corporation that has a full controlling interest prescribed in Article 57, paragraph (2) of the New Corporation Tax Act with a domestic corporation are determined, the provisions of paragraph (2) of the preceding Article do not apply to the individually attributed consolidated deficit that arose in each consolidated business year prior to the applicable consolidated business year of that consolidated corporation showing a loss, etc.

①In the case where there is a net operating loss that arose in a business year of a corporation that began before April 1, 2022, for business years beginning on or after that date, the provisions of Articles 57 and 58 of the New Corporation Tax Act apply by deeming the documents prescribed in Article 58, paragraph (5) of the Former Corporation Tax Act that were attached to the Final Return, amended return or written request for Reassessment for the business year in which that net operating loss arose to be the documents prescribed in Article 58, paragraph (3) of the New Corporation Tax Act.

②In applying the provisions of Article 57 of the New Corporation Tax Act to the net operating loss prescribed in the preceding paragraph, the amounts listed in the following items are deemed to be the amounts specified in the respective items:

③In the case where there is a net operating loss caused by a disaster that arose in a business year of a corporation that began before April 1, 2018 (excluding a business year for which a Blue Return is filed) (limited to a net operating loss caused by a disaster in the case where the Final Return, amended return or written request for Reassessment for the business year in which that net operating loss caused by a disaster arose has the attachment of the documents prescribed in Article 58, paragraph (5) of the 2015 Former Corporation Tax Act), for business years beginning on or after April 1, 2022, the provisions of Article 57 of the 2015 Former Corporation Tax Act (excluding paragraphs (3) and (4) of that Article) apply by deeming the business year in which that net operating loss caused by a disaster arose to be a business year for which a Blue Return is filed, and the amount equivalent to that net operating loss caused by a disaster to be a net operating loss that arose in that business year, respectively.

④In applying the provisions of Article 57 of the 2015 Former Corporation Tax Act to an amount deemed to be a net operating loss that arose in a business year for which a Blue Return is filed pursuant to the provisions of the preceding paragraph, the amounts listed in the following items are deemed to be the amounts specified in the respective items:

With regard to the application of the provisions of Article 59, paragraphs (1) through (4) of the New Corporation Tax Act, the net operating loss prescribed in those provisions is to include the individual net operating loss prescribed in Article 81-18, paragraph (1) of the Former Corporation Tax Act incurred in a consolidated business year (in the case where a consolidated deficit (meaning a consolidated deficit prescribed in Article 2, item (xix)-2 of the Former Corporation Tax Act; the same applies hereinafter in this Article and in Article 35, paragraph (2), item (ii), (a) of the Supplementary Provisions) arose in the consolidated business year, the amount obtained by adding the portion of the consolidated deficit attributable to the domestic corporation referred to in Article 59, paragraphs (1) through (4) of the New Corporation Tax Act).

Of the consolidated corporations showing a loss, etc. prescribed in Article 21, paragraph (2) of the Supplementary Provisions that are deemed to be corporations showing a loss, etc. prescribed in that paragraph pursuant to the provisions of that paragraph, those that held assets with unrealized losses prescribed in Article 60-3, paragraph (1) of the Former Corporation Tax Act or other assets specified by Cabinet Order as of the first day of the business year or consolidated business year containing the specified date of control prescribed in Article 57-2, paragraph (1) of the Former Corporation Tax Act are deemed to be corporations showing a loss, etc. prescribed in Article 60-3, paragraph (1) of the New Corporation Tax Act, and the provisions of that Article apply to them. In this case, the applicable consolidated business year prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act is deemed to be the applicable business year prescribed in Article 60-3, paragraph (1) of the New Corporation Tax Act, and the specified date of control prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act is deemed to be the date of control prescribed in Article 60-3, paragraph (1) of the New Corporation Tax Act, respectively.

①With regard to the application of the provisions of Article 61-11, paragraph (3) of the New Corporation Tax Act, the amount equivalent to the amount of gain on transfer or the amount of loss on transfer prescribed in that paragraph is not to include, out of the amount equivalent to the amount of gain on transfer prescribed in paragraph (1) of that Article or the amount of loss on transfer prescribed in that paragraph, the amount included in the amount of gross profits or the amount of deductible expenses in the calculation of the amount of consolidated income for each consolidated business year before the business year containing the preceding day prescribed in paragraph (3) of that Article.

②The provisions of Article 61-11, paragraph (4) of the New Corporation Tax Act apply to corporation tax on income for business years of a domestic corporation ending on or after March 31, 2022.

③With regard to the adjustment amount for gain or loss on transfer, as prescribed in Article 61-11, paragraph (4) of the New Corporation Tax Act, of a domestic corporation for which approval under Article 64-9, paragraph (1) of the New Corporation Tax Act is deemed to have been given pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, the provisions of Article 61-11, paragraph (4) of the New Corporation Tax Act do not apply.

④A domestic corporation that is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 61-11, paragraph (4) of the New Corporation Tax Act apply.

⑤With regard to the application of the provisions of Article 61-11, paragraph (4) of the New Corporation Tax Act, the amount equivalent to the amount of gain on transfer or the amount of loss on transfer prescribed in that paragraph is not to include, out of the amount equivalent to the amount of gain on transfer prescribed in paragraph (1) of that Article or the amount of loss on transfer prescribed in that paragraph, the amount included in the amount of gross profits or the amount of deductible expenses in the calculation of the amount of consolidated income for each consolidated business year before the fair valuation business year prescribed in paragraph (4) of that Article.

①With regard to the application of the provisions of Article 63, paragraph (3) of the New Corporation Tax Act, the amount of proceeds and the amount of expenses pertaining to a lease transfer prescribed in that paragraph are not to include, out of the amount of proceeds and the amount of expenses pertaining to a lease transfer prescribed in paragraph (1) of that Article, the amounts included in the amount of gross profits and the amount of deductible expenses in the calculation of the amount of consolidated income for each consolidated business year before the non-qualified share exchange, etc. business year prescribed in paragraph (3) of that Article.

②The provisions of Article 63, paragraph (4) of the New Corporation Tax Act apply to corporation tax on income for business years of a domestic corporation ending on or after March 31, 2022.

③With regard to the amount of proceeds and the amount of expenses prescribed in Article 63, paragraph (4) of the New Corporation Tax Act of a domestic corporation for which approval under Article 64-9, paragraph (1) of the New Corporation Tax Act is deemed to have been given pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, the provisions of that paragraph do not apply.

④A domestic corporation that is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 63, paragraph (4) of the New Corporation Tax Act apply.

⑤With regard to the application of the provisions of Article 63, paragraph (4) of the New Corporation Tax Act, the amount of proceeds and the amount of expenses pertaining to a lease transfer prescribed in that paragraph are not to include, out of the amount of proceeds and the amount of expenses pertaining to a lease transfer prescribed in paragraph (1) of that Article, the amounts included in the amount of gross profits and the amount of deductible expenses in the calculation of the amount of consolidated income for each consolidated business year before the fair valuation business year prescribed in paragraph (4) of that Article.

①With regard to the net operating loss before aggregation prescribed in Article 64-5, paragraph (1) of the New Corporation Tax Act of a group tax sharing corporation for which approval under Article 64-9, paragraph (1) of the New Corporation Tax Act is deemed to have been given pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, the provisions of Article 64-6, paragraph (1) of the New Corporation Tax Act do not apply.

②A domestic corporation that is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 64-6, paragraph (1) of the New Corporation Tax Act apply.

①With regard to the application of the provisions of Article 64-7 of the New Corporation Tax Act in the case where the provisions of Article 20, paragraph (1) or (4) of the Supplementary Provisions apply, the phrase "Article 57, paragraph (2)" in paragraph (1), item (ii), (a) of that Article is deemed to be replaced with "Article 57, paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Amending Act' in (2)) (Transitional Measures Concerning the Carryover of Losses)"; in item (ii), (a), (2) of that paragraph, "又は" (or) is deemed to be replaced with "若しくは" (or, joining a smaller group of alternatives); and the phrase "Article 58, paragraph (1) (Special Provisions on Losses for Business Years for Which No Blue Return Was Filed)" is deemed to be replaced with "Article 58, paragraph (1) (Special Provisions on Losses for Business Years for Which No Blue Return Was Filed) or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Amending Act".

②With regard to the application of the provisions of Article 64-7 of the New Corporation Tax Act pertaining to net operating losses incurred in business years that started before April 1, 2018, in paragraph (1) of that Article, the phrase "Article 57, paragraph (1) (Carryover of Losses)" is deemed to be replaced with "Article 57, paragraph (1) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 9 of 2015) in the case where the provisions then in force continue to govern pursuant to Article 27, paragraph (1) of the Supplementary Provisions of that Act (Transitional Measures Concerning the Carryover, etc. of Losses for Business Years for Which a Blue Return Was Filed) (hereinafter referred to as the '2015 Former Corporation Tax Act' in this Article) (Carryover of Losses for Business Years for Which a Blue Return Was Filed)"; in item (i) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act", the phrase "within ten years" is deemed to be replaced with "within nine years", the phrase "ten years before" is deemed to be replaced with "nine years before" and the phrase "parent corporation's business years within ten years, etc." is deemed to be replaced with "parent corporation's business years within nine years, etc."; in item (ii) of that paragraph, the phrase "within ten years" is deemed to be replaced with "within nine years" and the phrase "'business year within ten years'" is deemed to be replaced with "'business year within nine years'"; in item (ii), (a) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years" and the phrase "Article 57, paragraph (2)" is deemed to be replaced with "Article 57, paragraph (2) or (6) of the 2015 Former Corporation Tax Act or Article 20, paragraph (7) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Amending Act' in (2)) (Transitional Measures Concerning the Carryover of Losses)"; in item (ii), (a), (1) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (ii), (a), (2) of that paragraph, the phrase "Article 57, paragraphs (4) through (6), paragraph (8) or paragraph (9) or Article 58, paragraph (1) (Special Provisions on Losses for Business Years for Which No Blue Return Was Filed)" is deemed to be replaced with "Article 57, paragraph (4), (5) or (9) of the 2015 Former Corporation Tax Act, or Article 57, paragraph (6), (8) or (9) (Carryover of Losses) as applied with the replacement of terms pursuant to Article 20, paragraph (8) of the Supplementary Provisions of the 2020 Amending Act or paragraph (10) of that Article"; in item (ii), (a), (3) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (ii), (b) and (c), (1) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in item (ii), (c), (2), (i) and (ii) and (3), (i) and (ii) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years" and the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (iii) of that paragraph, the phrase "business year within ten years of a group tax sharing corporation" is deemed to be replaced with "business year within nine years of a group tax sharing corporation"; in item (iii), (a) of that paragraph, the phrase "the specified net operating loss incurred in the corresponding business year of the group tax sharing corporation pertaining to the business year within ten years" is deemed to be replaced with "the specified net operating loss incurred in the corresponding business year of the group tax sharing corporation pertaining to the business year within nine years" and the phrase "the amount of income before loss deduction pertaining to the business year within ten years (meaning, where calculated without applying the main clause of Article 57, paragraph (1)" is deemed to be replaced with "the amount of income before loss deduction pertaining to the business year within nine years (meaning, where calculated without applying the main clause of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (iii), (a), (2) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in item (iii), (a), (3) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years" and the phrase "the main clause of Article 57, paragraph (1)" is deemed to be replaced with "the main clause of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (iii), (b) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in item (iv) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (iv), (a) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in paragraph (2), item (i) of that Article, the phrase "ten years" is deemed to be replaced with "nine years"; in item (ii) of that paragraph and paragraph (3) of that Article, the phrase "Article 57, paragraph (2)" is deemed to be replaced with "Article 57, paragraph (2) of the 2015 Former Corporation Tax Act"; in paragraph (4) of that Article, the phrase "ten years" is deemed to be replaced with "nine years" and the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in paragraph (5) of that Article, the phrase "or, for each business year within ten years pertaining to the applicable business year," is deemed to be replaced with "or, for each business year within nine years pertaining to the applicable business year,", the phrase "in the documents attached to that return for each of the business years within ten years" is deemed to be replaced with "in the documents attached to that return for each of the business years within nine years" and the phrase ", the net operating loss to be included in deductible expenses under Article 57, paragraph (1)" is deemed to be replaced with ", the net operating loss to be included in deductible expenses under Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (i) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in item (ii) of that paragraph, the phrase "would be included in deductible expenses under Article 57, paragraph (1)" is deemed to be replaced with "would be included in deductible expenses under Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (ii), (a) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in item (ii), (b), (1), (i) and (2), (i) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in paragraph (6) of that Article, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years"; in paragraph (7), item (i) of that Article, the phrase "the main clause of Article 57, paragraph (1)" is deemed to be replaced with "the main clause of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in paragraph (9), item (ii) of that Article, the phrase "ten years" is deemed to be replaced with "nine years"; in item (iii) of that paragraph, the phrase "Article 57, paragraph (1)" is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act"; in item (iv) of that paragraph, the phrase "ten years" is deemed to be replaced with "nine years"; and in item (vii) of that paragraph, the phrase "business year within ten years" is deemed to be replaced with "business year within nine years".

③With regard to the application of the provisions of Article 64-7 of the New Corporation Tax Act to a domestic corporation for which approval under Article 64-9, paragraph (1) of the New Corporation Tax Act is deemed to have been given pursuant to the provisions of paragraph (1) of the following Article, the amount listed in paragraph (2), item (i) of that Article is, notwithstanding the provisions of that item, the amount, out of the amounts deemed to be net operating losses pursuant to the provisions of Article 20, paragraph (1) or (7) of the Supplementary Provisions, pertaining to the individually attributed amount of specified consolidated losses prescribed in Article 81-9, paragraph (3) of the Former Corporation Tax Act incurred in each consolidated business year of the domestic corporation whose consolidated parent corporation business year started before April 1, 2022.

④A domestic corporation that is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed to fall under the category of a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed not to fall under the category of a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 64-7, paragraph (2) of the New Corporation Tax Act apply.

①With regard to a domestic corporation that falls under the category of a consolidated parent corporation as of March 31, 2022 (excluding one whose approval under Article 4-2 of the Former Corporation Tax Act is rescinded after that date under the provisions then in force, which continue to govern pursuant to the provisions of Article 16, paragraph (1) or (2) of the Supplementary Provisions, and one that obtained approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act within the period of the consolidated parent corporation business year containing that date (including one that obtained approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act under the provisions then in force, which continue to govern pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions)) and a consolidated subsidiary corporation that has a consolidated full controlling interest with the domestic corporation as of the day of the end of the consolidated parent corporation business year containing that date, approval under Article 64-9, paragraph (1) of the New Corporation Tax Act is deemed to have been given on the day following that date. In this case, the approval becomes effective as of that day.

②In the case where a consolidated parent corporation has submitted to the competent district director with jurisdiction over the place for tax payment, by the day preceding the first day of the business year that first starts on or after April 1, 2022, a report stating that it is to be subject to the provisions of this paragraph and other matters specified by Ministry of Finance Order, the provisions of the preceding paragraph do not apply to the consolidated parent corporation and a consolidated subsidiary corporation that has a consolidated full controlling interest with the consolidated parent corporation as of that preceding day.

③A corporation that has been subject to the provisions of the preceding paragraph and for which the period from the day following the day of the end of the last consolidated business year until the day of the end of the business year containing the day on which five years have elapsed from that day has not yet elapsed is deemed to be a corporation listed in Article 64-9, paragraph (1), item (iii) of the New Corporation Tax Act, and the provisions of that Article apply.

④A corporation that has obtained approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act given under the provisions then in force, which continue to govern pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions; hereinafter referred to as "former approval" in this paragraph) and for which the period from the day following the day of the end of the business year containing the day on which it obtained the former approval until the day of the end of the business year containing the day on which five years have elapsed from that day has not yet elapsed is deemed to be a corporation listed in Article 64-9, paragraph (1), item (iii) of the New Corporation Tax Act, and the provisions of that Article apply.

⑤A corporation whose approval under Article 4-2 of the Former Corporation Tax Act was rescinded pursuant to the provisions of Article 4-5, paragraph (1) of the Former Corporation Tax Act (including a corporation whose approval under Article 4-2 of the Former Corporation Tax Act was rescinded under the provisions then in force, which continue to govern pursuant to the provisions of Article 16, paragraph (1) of the Supplementary Provisions) and for which the period from the date of rescission of those approvals until the day of the end of the business year containing the day on which five years have elapsed from that date has not yet elapsed is deemed to be a corporation listed in Article 64-9, paragraph (1), item (iv) of the New Corporation Tax Act, and the provisions of that Article apply.

⑥A domestic corporation that is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (3) or (5) of the following Article is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (3) or (5) of the following Article is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 64-9, paragraphs (7), (10) and (12) of the New Corporation Tax Act apply.

①The provisions of Article 64-11, paragraph (1) and Article 64-12, paragraph (1) of the New Corporation Tax Act apply to corporation tax on income for a business year of a domestic corporation ending on or after March 31, 2022.

②The provisions of Article 64-11, paragraph (1) of the New Corporation Tax Act do not apply to a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (1) of the preceding Article.

③In the case where, in a business year of a domestic corporation ending on March 31, 2022, the domestic corporation falls under a corporation listed in any of the following items, the provisions of Article 64-11, paragraph (1) of the New Corporation Tax Act may be applied by deeming the domestic corporation to be the domestic corporation specified in the relevant item:

④The provisions of Article 64-11, paragraph (2) of the New Corporation Tax Act do not apply to the shares of or capital contributions to a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (1) of the preceding Article.

⑤In the case where, in a business year of a domestic corporation ending on March 31, 2022, the domestic corporation falls under a corporation listed in any of the following items, the provisions of Article 64-12, paragraph (1) of the New Corporation Tax Act may be applied by deeming the domestic corporation to be the domestic corporation specified in the relevant item:

⑥Necessary matters concerning the application of the provisions of Article 64-11, paragraph (1) and Article 64-12, paragraph (1) of the New Corporation Tax Act to a corporation listed in paragraph (9), item (i) or paragraph (11), item (i) of Article 4-3 of the Former Corporation Tax Act in the case where the special business year for consolidated application prescribed in paragraph (6) of that Article is the business year that includes March 31, 2022, and other necessary matters concerning the application of the provisions of the preceding paragraphs, are specified by Cabinet Order.

①The provisions of Article 64-14 of the New Corporation Tax Act do not apply to the net operating loss on the transfer of specified assets prescribed in paragraph (2) of that Article of a group tax sharing corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions.

②A domestic corporation that is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (3) or (5) of the preceding Article is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of paragraph (3) or (5) of the preceding Article is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 64-14 of the New Corporation Tax Act apply.

①With regard to the application of the provisions of Article 69, paragraph (2) of the New Corporation Tax Act in the case where, among the business years that began within three years before the first day of the business year (limited to one beginning on or after April 1, 2022) in which a domestic corporation is to pay a creditable amount of the foreign country's corporate tax (meaning the creditable amount of the foreign country's corporate tax prescribed in Article 69, paragraph (1) of the New Corporation Tax Act; the same applies in this Article) (referred to as a "business year within preceding three years" in this paragraph), there is one that falls under a consolidated business year, and there is an individually attributed amount of the consolidated credit limit (meaning the individually attributed amount of the consolidated credit limit prescribed in Article 81-15, paragraph (1) of the Former Corporation Tax Act; the same applies in this Article) for that consolidated business year, that individually attributed amount of the consolidated credit limit is deemed to be the limitation on a creditable amount (meaning the limitation on a creditable amount prescribed in paragraph (1) of that Article; the same applies in this Article) for the business year within preceding three years corresponding to the period of that consolidated business year; and with regard to the application of the provisions of Article 69, paragraph (3) of the New Corporation Tax Act in the case where there is an individually creditable amount of the foreign country's corporate tax (meaning the individually creditable amount of the foreign country's corporate tax prescribed in Article 81-15, paragraph (1) of the Former Corporation Tax Act; the same applies in this Article) that came to be paid in that consolidated business year, that individually creditable amount of the foreign country's corporate tax is deemed to be a creditable amount of the foreign country's corporate tax that came to be paid in the business year within preceding three years corresponding to the period of that consolidated business year.

②With regard to the application of the provisions of Article 69, paragraph (9) of the New Corporation Tax Act, the limitation on a creditable amount or the creditable amount of the foreign country's corporate tax for a business year within three years before the merger (meaning a business year within three years before the merger prescribed in item (i) of that paragraph; the same applies in this paragraph) of an acquired corporation prescribed in that item is to include the individually attributed amount of the consolidated credit limit or the individually creditable amount of the foreign country's corporate tax for that business year within three years before the merger, and the limitation on a creditable amount or the creditable amount of the foreign country's corporate tax for a business year within three years before the company split, etc. (meaning a business year within three years before the company split, etc. prescribed in item (ii) of that paragraph; the same applies in this paragraph) of a splitting corporation, etc. prescribed in paragraph (9), item (ii) of that Article is to include the individually attributed amount of the consolidated credit limit or the individually creditable amount of the foreign country's corporate tax for that business year within three years before the company split, etc.

③With regard to the application of the provisions of Article 69, paragraph (11) of the New Corporation Tax Act, an amount deemed to be the limitation on a creditable amount prescribed in that paragraph is to include an amount deemed to be the individually attributed amount of the consolidated credit limit for a consolidated business year within preceding three years (meaning a consolidated business year within preceding three years prescribed in Article 81-15, paragraph (2) of the Former Corporation Tax Act; the same applies in this paragraph) pursuant to the provisions of Article 81-15, paragraph (5) of the Former Corporation Tax Act, and an amount deemed to be the creditable amount of the foreign country's corporate tax prescribed in Article 69, paragraph (11) of the New Corporation Tax Act is to include an amount deemed to be the individually creditable amount of the foreign country's corporate tax that came to be paid in a consolidated business year within preceding three years pursuant to the provisions of Article 81-15, paragraph (5) of the Former Corporation Tax Act.

④With regard to the application of the provisions of Article 69, paragraph (12) of the New Corporation Tax Act, the applicable business year prescribed in that paragraph is to include a consolidated business year for which the provisions of Article 81-15, paragraphs (1) through (3) of the Former Corporation Tax Act were applied.

⑤With regard to the application of the provisions of Article 69, paragraph (26) of the Corporation Tax Act in the case where, among the business years of a domestic corporation that began before April 1, 2022 (including a business year for which the consolidated parent corporation business year of a consolidated subsidiary corporation began before that date), there is one that falls under a consolidated business year, the phrase "the returns, etc. for each business year on or after the oldest of the business years" in that paragraph is deemed to be replaced with "the Final Returns, consolidated tax returns (meaning consolidated tax returns prescribed in Article 2, item (xxxii) (Definitions) of the Former Corporation Tax Act; the same applies in this paragraph), amended returns or written requests for Reassessment for each business year or each consolidated business year on or after the oldest of the business years or consolidated business years (meaning consolidated business years prescribed in Article 15-2 (Meaning of Consolidated Business Year) of the Corporation Tax Act prior to the amendment by Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020) (referred to as the 'Former Corporation Tax Act' in this paragraph); the same applies in this paragraph)", the phrase "stating the limitation on a creditable amount for each business year and the creditable amount of the foreign country's corporate tax to be paid in each business year" with "stating the limitation on a creditable amount for each business year and the creditable amount of the foreign country's corporate tax to be paid in each business year, or the individually attributed amount of the consolidated credit limit for each such consolidated business year (meaning the individually attributed amount of the consolidated credit limit prescribed in Article 81-15, paragraph (1) (Foreign Tax Credit in a Consolidated Business Year) of the Former Corporation Tax Act; the same applies in this paragraph) and the individually creditable amount of the foreign country's corporate tax to be paid in each such consolidated business year (meaning the individually creditable amount of the foreign country's corporate tax prescribed in paragraph (1) of that Article; the same applies in this paragraph)", the phrase "are, except where the district director" with "or the individually attributed amount of the consolidated credit limit for each such consolidated business year, the individually creditable amount of the foreign country's corporate tax to be paid in each such consolidated business year and other amounts specified by Ministry of Finance Order are, except where the district director", and the phrase "attached to the returns, etc. for each business year" with "attached to the Final Returns, consolidated tax returns, amended returns or written requests for Reassessment for each business year or each consolidated business year".

①In a business year prescribed in Article 71, paragraph (1) of the New Corporation Tax Act of an ordinary corporation set forth in that paragraph that begins on or after April 1, 2022, if the period of the previous business year of that business year falls under a consolidated business year, then with regard to the interim return for that business year to be filed by the ordinary corporation, the amount listed in item (i) of that paragraph is, notwithstanding the provisions of that item, the amount calculated by dividing the individually attributed payment of consolidated corporation tax prescribed in Article 71, paragraph (1), item (i) of the Former Corporation Tax Act pertaining to the ordinary corporation for that previous business year (referred to as the "individually attributed payment of consolidated corporation tax" in the following paragraph) that pertains to the amount listed in Article 81-22, paragraph (1), item (ii) of the Former Corporation Tax Act to be stated in the consolidated tax return for that previous business year that was finalized by the day before the day on which six months have elapsed prescribed in Article 71, paragraph (1) of the New Corporation Tax Act (referred to as the "day on which six months have elapsed" in the following paragraph and paragraph (4)), by the number of months of that previous business year, and multiplying the result by the number of months of the interim period prescribed in Article 71, paragraph (1), item (i) of the New Corporation Tax Act.

②In the case referred to in Article 71, paragraph (1) of the New Corporation Tax Act, when the ordinary corporation set forth in that paragraph is the acquiring corporation in a qualified merger (excluding one that establishes a corporation) carried out within a period listed in any of the items of paragraph (2) of that Article or the acquiring corporation in a qualified merger that establishes a corporation (limited to the case where, of the business years (excluding those of less than six months) of the acquired corporation in those qualified mergers that ended on or after the day one year before the first day of that business year of the ordinary corporation, the period of the most recent business year falls under a consolidated business year), then, with regard to the application of the provisions of that paragraph and paragraph (3) of that Article, the finalized corporation tax amount of the acquired corporation prescribed in paragraph (2), item (i) of that Article of that acquired corporation is the individually attributed payment of consolidated corporation tax of that acquired corporation for that most recent business year that pertains to the amount listed in Article 81-22, paragraph (1), item (ii) of the Former Corporation Tax Act to be stated in the consolidated tax return for that most recent business year that was finalized by the day before the day on which six months have elapsed.

③The number of months set forth in the preceding two paragraphs is calculated according to the calendar and a division of less than one month is counted as one month.

④In the case where the due date for filing a return under Article 81-22, paragraph (1) of the Former Corporation Tax Act for a business year that falls under the consolidated business year set forth in paragraph (1) has been extended by four months pursuant to the provisions of Article 81-24, paragraph (1) of the Former Corporation Tax Act, and the provisions of Article 10, paragraph (2) of the Act on General Rules for National Taxes apply to the due date for filing that return, if the amount listed in Article 81-22, paragraph (1), item (ii) of the Former Corporation Tax Act to be stated in the consolidated tax return is finalized during the period from the day following the due date for filing that return that would apply if the provisions of that paragraph did not apply, until the day deemed to be the due date for filing that return pursuant to the provisions of that paragraph, the provisions of paragraphs (1) and (2) apply by deeming that amount to have been finalized by the day before the day on which six months have elapsed.

①In the case where a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions (limited to one that was a consolidated parent corporation; referred to as a "transitioned corporation" in this Article) was subject to the provisions of Article 81-24, paragraph (1) of the Former Corporation Tax Act in the consolidated business year that includes March 31, 2022, the transitioned corporation and any domestic corporation that had a consolidated full controlling interest with the transitioned corporation on the last day of that consolidated business year (excluding one that ceased to have a group tax sharing full controlling interest with the transitioned corporation on the day following that day) are deemed to have had the due date for filing under Article 75-2, paragraph (1) of the New Corporation Tax Act extended on that following day.

②In the case where a transitioned corporation had received a designation under any of the items of Article 81-24, paragraph (1) of the Former Corporation Tax Act in the consolidated business year that includes March 31, 2022, the transitioned corporation and any domestic corporation that had a consolidated full controlling interest with the transitioned corporation on the last day of that consolidated business year (excluding one that ceased to have a group tax sharing full controlling interest with the transitioned corporation on the day following that day) are deemed to have received, on that following day, the designation under the relevant item of Article 75-2, paragraph (1) of the New Corporation Tax Act as applied with the replacement of terms pursuant to the provisions of paragraph (11), item (i) of that Article, with the number of months pertaining to that designation as the number of months pertaining to the designation under that item.

①With regard to the application of the provisions of Article 80, paragraph (4) of the New Corporation Tax Act in the case where the provisions of Article 20, paragraph (4) of the Supplementary Provisions apply, the phrase "or paragraph (5)" in that paragraph is deemed to be replaced with "or paragraph (5), or Article 20, paragraph (4) (Transitional Measures for Carryover of Losses) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020)".

②With regard to the application of the provisions of Article 80 of the New Corporation Tax Act in the case where each business year that began within two years before the first day of the business year showing a loss prescribed in Article 80, paragraph (1) of the New Corporation Tax Act (including as applied mutatis mutandis pursuant to paragraph (5) of that Article) (referred to as the "business year showing a loss" in item (iii)) of a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions (referred to as a "business year within preceding two years" in this paragraph) is a consolidated business year, the amounts listed in the following items are deemed to be the amounts specified in the respective items, a consolidated tax return is deemed to be a Final Return that is a Blue Return, and that business year within preceding two years is deemed to be a business year that does not fall under a business year that ended before the day on which the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act became effective, respectively:

①In the case where the approval under Article 4-2 of the Former Corporation Tax Act of a domestic corporation has been revoked pursuant to the provisions of Article 4-5, paragraph (2) of the Former Corporation Tax Act (including the case where the approval under Article 4-2 of the Former Corporation Tax Act has been revoked as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (2) of the Supplementary Provisions), or where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions), when it seeks to obtain the approval set forth in Article 121, paragraph (1) of the Former Corporation Tax Act for filing the returns listed in the items of that paragraph for each business year on or after the business year listed in Article 122, paragraph (2), items (vi) through (viii) of the Former Corporation Tax Act via a Blue Return, the provisions then in force continue to govern the due date for filing the application form under Article 122, paragraph (1) of the Former Corporation Tax Act and the day on which approval is deemed to have been given pursuant to the provisions of Article 125 of the Former Corporation Tax Act.

②The due date for filing the application form under Article 122, paragraph (1) of the New Corporation Tax Act when a domestic corporation to which the provisions of Article 29, paragraph (2) of the Supplementary Provisions have been applied seeks to obtain the approval set forth in Article 121, paragraph (1) of the New Corporation Tax Act for filing the returns listed in the items of that paragraph for each business year on or after the following business year of its final consolidated business year via a Blue Return is, notwithstanding the provisions of Article 122, paragraph (1), the day before whichever is earlier of the day on which three months have elapsed from the first day of that following business year and the last day of that following business year.

③With regard to the application of the provisions of Article 127 of the New Corporation Tax Act to a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, the phrase "paragraph (1) of the preceding Article" in paragraph (1), item (i) of that Article is deemed to be replaced with "paragraph (1) of the preceding Article or Article 4-4, paragraph (1) (Retention of Books and Documents of Consolidated Corporations) of the Corporation Tax Act prior to the amendment by Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020) (referred to as the 'Former Corporation Tax Act' in this paragraph)"; the phrase "the instructions of the district director of the tax office given pursuant to the provisions of paragraph (2) of the preceding Article" in item (ii) of that paragraph is deemed to be replaced with "the instructions of the district director of the tax office given pursuant to the provisions of paragraph (2) of the preceding Article or the instructions of the Commissioner of the National Tax Agency, the regional commissioner or the district director given pursuant to the provisions of Article 4-4, paragraph (2) of the Former Corporation Tax Act"; the phrase "a return under Article 74, paragraph (1) (Final Returns)" in item (iv) of that paragraph is deemed to be replaced with "a return under Article 74, paragraph (1) (Final Returns) or a return under Article 81-22, paragraph (1) (Consolidated Final Returns) of the Former Corporation Tax Act", and the phrase "pertaining to the return" with "pertaining to those returns"; and the phrase "又は" (or) in paragraphs (3) and (4) of that Article is deemed to be replaced with "若しくは" (or, joining a smaller group of alternatives).

①In the case where the final consolidated business year (meaning a consolidated business year ending on or after March 31, 2022; the same applies in this paragraph) of a consolidated parent corporation has ended, the provisions of Article 135 of the Former Corporation Tax Act that remain in force pursuant to the provisions of Article 14, paragraph (2) of the Supplementary Provisions apply by deeming that ending to be a fact listed in any of the items of Article 135, paragraph (3) of the Former Corporation Tax Act, and by deeming the due date for filing the return under Article 81-22, paragraph (1) of the Former Corporation Tax Act for that final consolidated business year to be the final filing due date prescribed in Article 135, paragraph (3) of the Former Corporation Tax Act.

②With regard to a claim for a refund under Article 135, paragraph (4) of the Former Corporation Tax Act made by a consolidated parent corporation before the due date for filing prescribed in the preceding paragraph, the provisions then in force continue to govern.

①The provisions of Article 28, paragraph (7) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. as amended by Article 30 (referred to as the "New 2018 Amendment Act" in this Article) apply to corporation tax on income for a business year of a domestic corporation ending on or after March 31, 2022.

②The provisions of Article 28, paragraph (7) of the Supplementary Provisions of the New 2018 Amendment Act do not apply to the amount of proceeds and the amount of expenses prescribed in that paragraph of a domestic corporation deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions.

③A domestic corporation that is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and a domestic corporation that is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively, and the provisions of Article 28, paragraph (7) of the Supplementary Provisions of the New 2018 Amendment Act apply.

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; hereinafter the same applies 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 and in the cases where provisions remain in force 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.