Article 222Calculation of the Maximum Credit

①The amount calculated as specified by Cabinet Order prescribed in Article 95, paragraph (1) (Foreign Tax Credit) of the Act is to be the amount calculated by multiplying the amount of income tax for that year of the Resident referred to in that paragraph (meaning the amount of income tax calculated without applying that Article, and excluding the amount of accessory tax) by the proportion that the adjusted amount of foreign-source income for that year bears to the aggregate income for that year.

②The aggregate income for that year prescribed in the preceding paragraph is to be the sum of the gross income, the amount of retirement income and the amount of timber income for that year calculated without applying Article 70, paragraph (1) or (2) (Deduction for Carryover of Net Loss) or Article 71 (Deduction for Carryover of Casualty Loss) of the Act (referred to in the following paragraph as the "aggregate income for the year").

③The adjusted amount of foreign-source income for that year prescribed in paragraph (1) means the amount of foreign-source income for that year prescribed in Article 95, paragraph (1) of the Act (for a Non-Permanent Resident, limited, out of that amount of foreign-source income, to the portion pertaining to foreign source income paid in Japan or remitted from outside Japan; the same applies hereinafter in this paragraph) calculated without applying Article 70, paragraph (1) or (2) or Article 71 of the Act; provided, however, that where that amount of foreign-source income exceeds the amount equivalent to the aggregate income for the year, it is the amount equivalent to the aggregate income for the year.