This Act comes into effect on April 1, 2025; provided, however, that the provisions set forth in the following items come into effect as of the dates specified respectively in those items.

Except as otherwise provided for in these Supplementary Provisions, the provisions of the Corporation Tax Act as amended by the provisions of Article 2 (limited to the amending provisions listed in Article 1, item (iii), (b) of the Supplementary Provisions) (hereinafter referred to as the "Corporation Tax Act as Amended for 2026") apply to corporation tax on the international minimum tax amount of a domestic corporation for a covered fiscal year beginning on or after April 1, 2026, corporation tax on the international minimum tax residual amount of a corporation (including an association or foundation without juridical personality; hereinafter the same applies through Article 17 of the Supplementary Provisions) for a covered fiscal year beginning on or after that date, and corporation tax on the domestic minimum tax amount of a corporation for a covered fiscal year beginning on or after that date, and with regard to corporation tax on the international minimum tax amount of a domestic corporation for a covered fiscal year that began before that date, the provisions then in force continue to govern.

The provisions of Article 53 of the Corporation Tax Act as amended by the provisions of Article 2 (hereinafter referred to as the "New Corporation Tax Act") apply to corporation tax on income for a business year of a corporation beginning on or after the Effective Date.

The provisions of Article 61-2, paragraph (20) of the Corporation Tax Act as Amended for 2026 apply to a refund prescribed in that paragraph made on or after April 1, 2026.

The provisions of Article 62-8, paragraph (1) of the New Corporation Tax Act apply to a non-qualified merger, etc. prescribed in that paragraph carried out on or after the Effective Date, and with regard to a non-qualified merger, etc. prescribed in Article 62-8, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 (hereinafter referred to as the "Former Corporation Tax Act") carried out before the Effective Date, the provisions then in force continue to govern.

①With regard to corporation tax on income for a business year that began before the Effective Date of a corporation that carried out a lease transfer prescribed in Article 63, paragraph (1) of the Former Corporation Tax Act before the Effective Date, the provisions then in force continue to govern.

②With regard to the calculation of the amount of income pertaining to former lease transfers (meaning lease transfers prescribed in Article 63, paragraph (1) of the Former Corporation Tax Act carried out in a business year that began on or before March 31, 2027; hereinafter the same applies in this Article) for a business year beginning on or after the Effective Date (referred to as a "business year under the transitional measures" in the following paragraph and paragraph (4)) of a corporation that has carried out a lease transfer prescribed in Article 63, paragraph (1) of the Former Corporation Tax Act before the Effective Date (including a corporation that has received a transfer of a contract pertaining to a lease transfer prescribed in that paragraph carried out before the Effective Date), the provisions of Article 63 of the Former Corporation Tax Act (including the case where the calculation is made in accordance with it pursuant to the provisions of Article 142, paragraph (2) of the Former Corporation Tax Act) remain in force. In this case, the phrase "or where the provisions of paragraph (3) or (4)" in the proviso to Article 63, paragraph (1) of the Former Corporation Tax Act is deemed to be replaced with "(excluding the case falling under the case listed in Article 17, paragraph (3), item (i) (Transitional Measures for the Business Year for Vesting Profits and Expenses Related to Lease Transfers) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2025; hereinafter referred to as the "2025 Amendment Act" in this paragraph and the following paragraph)) or where the provisions of paragraph (3) or (4) or the provisions of Article 17, paragraph (3) or (4) of the Supplementary Provisions of the 2025 Amendment Act", the phrase "after the business year when any of these provisions were applied" with "after the business year when the provisions of paragraph (3) or (4) were applied or on or after the base business year prescribed in paragraph (3) of that Article", the phrase "or paragraph (4)" in the proviso to paragraph (2) of that Article with "or paragraph (4), or the provisions of Article 17, paragraph (3) or (4) of the Supplementary Provisions of the 2025 Amendment Act", the phrase "after the business year when any of these provisions were applied" with "after the business year when the provisions of the following paragraph or paragraph (4) were applied or on or after the base business year prescribed in paragraph (3) of that Article", the phrase "the amount of income for each business year" in paragraph (3) of that Article with "the amount of income or the amount of consolidated income (meaning consolidated income prescribed in Article 2, item (xviii)-4 (Definitions) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies in the following paragraph) for each business year or each consolidated business year (meaning a consolidated business year prescribed in Article 15-2, paragraph (1) (Meaning of Consolidated Business Year) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies in the following paragraph)", and the phrase "the amount of income for each business year" in paragraph (4) of that Article with "the amount of income or the amount of consolidated income for each business year or each consolidated business year".

③In the case where the amount of proceeds and the amount of expenses pertaining to former lease transfers of a corporation subject to the provisions of the main clause of Article 63, paragraph (1) or the main clause of paragraph (2) of the Former Corporation Tax Act that remains in force pursuant to the provisions of the preceding paragraph (hereinafter referred to as the "Former Corporation Tax Act Kept in Force" in this paragraph and the following paragraph) (including the case where the calculation is made in accordance with these provisions pursuant to the provisions of Article 142, paragraph (2) of the Former Corporation Tax Act; hereinafter the same applies in this paragraph and the following paragraph), to which that application pertains, fall under any of the cases listed in the following items, that amount of proceeds and that amount of expenses (excluding those included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for each business year that began before the first day of the business year specified in the relevant item or the amount of consolidated income (meaning consolidated income prescribed in Article 2, item (xviii)-4 of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies in item (ii)) for each consolidated business year (meaning a consolidated business year prescribed in Article 15-2, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020); the same applies in item (ii)) that began before that date; referred to as "unrecognized revenue" and "unrecognized expenses", respectively, in the following paragraph) are included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for the business year specified in the relevant item (referred to as the "base business year" in the following paragraph and paragraph (5)).

④In the case where the amount of proceeds and the amount of expenses pertaining to former lease transfers of a corporation subject to the provisions of the main clause of Article 63, paragraph (1) or the main clause of paragraph (2) of the Former Corporation Tax Act Kept in Force, to which that application pertains, fall under any of the cases listed in the items of the preceding paragraph, if the unrecognized revenue pertaining to that former lease transfer exceeds the unrecognized expenses pertaining to that former lease transfer, notwithstanding the provisions of that paragraph, the amounts listed in item (i) (for the business year that includes the date of dissolution or of the discontinuation or transfer of the whole of its business (excluding a transfer to a succeeding corporation in a company split as a result of a qualified company split or any other transfer specified by Cabinet Order), a business year in liquidation or the business year that includes the day preceding the date of the merger of an acquired corporation (excluding a qualified merger), the business year that includes the day preceding the day on which an ordinary corporation or a cooperative, etc. comes to fall under a public interest corporation, etc. in the case where it so comes to fall, and a business year in which the amounts listed in that item respectively exceed the amounts listed in item (ii), the amounts listed in item (ii)) are included in the amount of gross profit and the amount of deductible expenses when calculating the amount of income for each business year under the transitional measures on or after the base business year:

⑤The provisions of the preceding paragraph apply only in the case where the Final Return for the base business year (in the case of filing an interim return for the base business year stating the matters listed in the items of Article 72, paragraph (1) or the items of Article 144-4, paragraph (1) or (2) of the Corporation Tax Act, that interim return; the same applies in the following paragraph) contains a statement of the amounts to be included in the amount of gross profit and the amount of deductible expenses pursuant to the provisions of the preceding paragraph.

⑥Even in the case where a Final Return without entries for the matters set forth in the preceding paragraph has been filed, the district director may apply the provisions of paragraph (4), when they find any unavoidable grounds for the person's failure to make entries for such matters.

⑦The number of months referred to in paragraph (4), item (i) is calculated according to the calendar, and any fraction of less than one month is rounded down.

⑧Special provisions on the treatment of the amount of proceeds and the amount of expenses pertaining to a former lease transfer in the case where a contract pertaining to that former lease transfer has been transferred as a result of a qualified merger, qualified company split or qualified capital contribution in kind, and other necessary matters concerning the application of the provisions of paragraphs (2) through (4), are specified by Cabinet Order.