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 transfer gain or loss adjustment amount 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 business year of fair valuation prescribed in paragraph (4) of that Article.