Supplementary Provisions, Article 12Transitional Provisions Concerning Foreign Tax Credit

In applying the provisions of Article 224, paragraphs (1) through (3) (Maximum Carry-Over Credit, etc.) or Article 225 (Foreign Income Tax Carried Over, etc.) of the New Order, the unused portion within the maximum creditable amount for national tax, the unused portion within the maximum creditable amount for local taxes, or the amount exceeding the credit limit prescribed in Article 12-31, items (iv) through (vi) (Meaning of Terms Concerning Foreign Tax Credit) of the Former Order for each year up to and including 1964 are deemed to be, respectively, the unused portion within the maximum creditable amount for national tax, the unused portion within the maximum creditable amount for local taxes, or the amount exceeding the credit limit prescribed in Article 224, paragraphs (4) through (6) of the New Order for each of those years. In this case, of those amounts, the amounts deemed not to exist pursuant to Article 12-33, paragraph (4) (Calculation of Amounts to Be Added to the Maximum Foreign Tax Credit for National Tax, etc.) or Article 13, paragraph (3) or (4) (Calculation of Amounts of Foreign Income Tax Carried Over for Deduction) of the Former Order are deemed to be amounts deemed not to exist pursuant to Article 224, paragraph (3) or Article 225, paragraph (3) or (4) of the New Order, respectively.