Order for Enforcement of the Income Tax Act

In the case where, with respect to shares held by a Resident, a split or consolidation of those shares (hereinafter in this paragraph referred to as "old shares") has occurred, for the calculation of the assessed value of the shares held after the split or consolidation (meaning shares of the corporation that issued the old shares that the Resident holds immediately after that split or consolidation; the same applies hereinafter in this paragraph) under Article 105, paragraph (1) (Valuation Methods for Securities) for each year on or after the year in which the day of that split or consolidation falls, the acquisition price per share (per unit for capital contributions and investment units; the same applies hereinafter in this Division) of the shares held after the split or consolidation that forms the basis for that calculation is to be the amount calculated by multiplying the previous acquisition price of one old share by the number of old shares and dividing the result by the number of shares held after the split or consolidation, and, if old shares are included in the shares held after the split or consolidation, those old shares are deemed to have been acquired on that same day.

In the case where, with respect to beneficial interests in an Investment Trust or a Specified Trust That Issues Beneficiary Certificates held by a Resident, a split or consolidation of those beneficial interests (hereinafter in this paragraph referred to as "old beneficial interests") has occurred, for the calculation of the assessed value of the beneficial interests held after the split or consolidation (meaning beneficial interests in the Investment Trust or the Specified Trust That Issues Beneficiary Certificates pertaining to the old beneficial interests that the Resident holds immediately after that split or consolidation; the same applies hereinafter in this paragraph) under Article 105, paragraph (1) for each year on or after the year in which the day of that split or consolidation falls, the acquisition price per unit of the beneficial interests held after the split or consolidation that forms the basis for that calculation is to be the amount calculated by multiplying the previous acquisition price of one unit of old beneficial interests by the number of units of old beneficial interests and dividing the result by the number of units of beneficial interests held after the split or consolidation, and, if old beneficial interests are included in the beneficial interests held after the split or consolidation, those old beneficial interests are deemed to have been acquired on that same day.

In the case where a Resident has acquired, with respect to shares held by the Resident (hereinafter in this paragraph referred to as "old shares"), shares allotted in proportion to the number of those old shares (limited to the case where payment of money is required for the shares so acquired (hereinafter in this paragraph referred to as "new shares")), for the calculation of the assessed value of those shares under Article 105, paragraph (1) (Valuation Methods for Securities) for each year on or after the year in which the due date for that payment (if a period for payment is specified, the day on which that payment was made) falls, the acquisition price per share of the old shares and the new shares that forms the basis for that calculation is to be the amount calculated by dividing the sum of the previous acquisition price of one old share and the amount calculated by multiplying the amount of money paid for one new share (if there are expenses required for the acquisition through that payment of money, the amount obtained by adding the amount of those expenses) by the number of new shares acquired for one old share, by the number obtained by adding one to the number of new shares acquired for one old share, and those old shares are deemed to have been acquired on that same day.

In the case where a Resident has acquired, with respect to shares held by the Resident (hereinafter in this paragraph referred to as "old shares"), shares allotted in proportion to the number of those old shares through a gratis allotment of shares by the corporation that issued those old shares (meaning the allotment by a corporation of its own shares to its Shareholders, Members, or Other Investors without requiring any new payment; the same applies hereinafter in this paragraph) (limited to the case where shares of the same class of shares as those old shares have been acquired), for the calculation of the assessed value of the shares held after the gratis allotment (meaning shares of the corporation that issued the old shares that the Resident holds immediately after that gratis allotment of shares; the same applies hereinafter in this paragraph) under Article 105, paragraph (1) for each year on or after the year in which the day of that gratis allotment of shares falls, the acquisition price per share of the shares held after the gratis allotment that forms the basis for that calculation is to be the amount calculated by multiplying the previous acquisition price of one old share by the number of old shares and dividing the result by the number of shares held after the gratis allotment, and, if old shares are included in the shares held after the gratis allotment, those old shares are deemed to have been acquired on that same day.

In the case where a Resident has acquired, with respect to shares held by the Resident (hereinafter in this paragraph referred to as "old shares"), shares of the acquiring corporation or shares of the parent corporation of the acquiring corporation from the acquiring corporation through a merger of the corporation that issued the old shares (including a merger of trusts pertaining to a Trust Subject to Corporate Taxation; limited to a merger in which no assets other than shares of any one of the acquiring corporation (meaning the acquiring corporation prescribed in Article 61, paragraph (6), item (x) pertaining to that merger; hereinafter in this paragraph and the following paragraph referred to as the "acquiring corporation") and a corporation that has, with the acquiring corporation, a relationship specified by Ministry of Finance Order as a relationship in which one directly or indirectly holds all of the issued shares or capital contributions of the acquiring corporation (excluding own shares held by itself; hereinafter in paragraphs (1) and (4) of the following Article and Article 113-2, paragraph (3) (Acquisition Price of Shares, etc. Acquired Through a Share Distribution) referred to as the "issued shares, etc.") (hereinafter in this paragraph referred to as the "parent corporation of the acquiring corporation") have been delivered to the Shareholders, Members, or Other Investors of the merged corporation prescribed in Article 61, paragraph (6), item (v) (Method of Calculating the Amount of Stated Capital, etc. Corresponding to Shares Held, etc.) pertaining to that merger (hereinafter in the following paragraph referred to as the "merged corporation") (excluding money or other assets delivered to those Shareholders, Members, or Other Investors as a dividend of surplus, dividend of profits, or distribution of surplus in respect of shares, and money or other assets delivered to those Shareholders, Members, or Other Investors who object to the merger as consideration based on their purchase demand)), for the calculation of the assessed value of the shares of the acquiring corporation or the shares of the parent corporation of the acquiring corporation under Article 105, paragraph (1) (Valuation Methods for Securities) for each year on or after the year in which the day of that merger falls, the acquisition price per share of the acquired shares of the acquiring corporation (hereinafter in this paragraph referred to as "acquiring corporation shares") or shares of the parent corporation of the acquiring corporation (hereinafter in this paragraph referred to as "shares of the parent corporation of the acquiring corporation") that forms the basis for that calculation is to be the amount calculated by dividing the previous acquisition price of one old share (if there is an amount deemed to have been received as a dividend of surplus, dividend of profits, distribution of surplus, or distribution of monies pursuant to Article 25, paragraph (1), item (i) (Deemed Dividends in the Case of a Merger) of the Act, or an amount of expenses required for the acquisition of those acquiring corporation shares or shares of the parent corporation of the acquiring corporation, the amount obtained by adding the portion of that amount deemed to have been received and that amount of expenses that corresponds to one old share) by the number of acquiring corporation shares or shares of the parent corporation of the acquiring corporation acquired for one old share.

In the case where, with regard to shares held by a Resident (hereinafter in this paragraph referred to as "shares held"), a merger in which the corporation that issued the shares held is the acquiring corporation (including a merger of trusts pertaining to a Trust Subject to Corporate Taxation, and limited to a merger that falls under a merger without consideration prescribed in Article 4-3, paragraph (2), item (i) (Shareholding Relationships, etc. in Qualified Reorganizations) of the Order for the Enforcement of the Corporation Tax Act and that has the relationship set out in item (ii), (b) of that paragraph; hereinafter in this paragraph referred to as "merger without consideration") has taken place, for the calculation of the assessed value of the shares held under Article 105, paragraph (1) in each year on or after the year that includes the date of that merger without consideration, the acquisition price per share of the shares held that serves as the basis of that calculation is the amount obtained by adding, to the previous acquisition price of one of the shares held, the amount calculated by multiplying the previous acquisition price of one old share (meaning shares of the merged corporation pertaining to that merger without consideration that the Resident held immediately before that merger without consideration; the same applies hereinafter in this paragraph) (where there is an amount deemed to have been received as a dividend of surplus, dividend of profits, or distribution of surplus pursuant to Article 25, paragraph (1), item (i) of the Act, the amount obtained by adding the portion of that amount deemed to have been received that corresponds to one old share) by the number of those old shares and dividing the result by the number of the shares held, and the shares held are deemed to have been acquired on that date.

In the case where a Resident, with regard to a beneficial interest (hereinafter in this paragraph referred to as "old beneficial interest") in an Investment Trust or a Specified Trust That Issues Beneficiary Certificates (hereinafter in this paragraph referred to as "Investment Trust, etc.") held by the Resident, acquires a beneficial interest in a consolidated Investment Trust, etc. from the consolidated Investment Trust, etc. through a merger of trusts of the Investment Trust, etc. pertaining to that old beneficial interest (limited to a merger of trusts in which no assets other than a beneficial interest in the Investment Trust, etc. that is the new trust pertaining to that merger (hereinafter in this paragraph referred to as "consolidated Investment Trust, etc.") are delivered to the beneficiaries of the former Investment Trust, etc. pertaining to that merger of trusts (excluding money or other assets delivered as consideration based on a purchase request made by such a beneficiary who opposes the merger of trusts)), for the calculation of the assessed value of the beneficial interest in the consolidated Investment Trust, etc. under Article 105, paragraph (1) in each year on or after the year that includes the date of that merger of trusts, the acquisition price per unit of the acquired beneficial interest in the consolidated Investment Trust, etc. that serves as the basis of that calculation is the amount calculated by dividing the previous acquisition price of one unit of the old beneficial interest (where there is an amount of expenses required for the acquisition of that beneficial interest in the consolidated Investment Trust, etc., the amount obtained by adding the portion of that amount of expenses that corresponds to one unit of the old beneficial interest) by the number of units of beneficial interest in the consolidated Investment Trust, etc. acquired for one unit of the old beneficial interest.