Supplementary Provisions, Article 18Transitional Measures Concerning Taxable Income of Nonresidents without a Permanent Establishment

①The provisions of Article 291, paragraphs (1), (8) and (9) (Taxable Income of Nonresidents Without a Permanent Establishment) of the New Order apply to income from the transfer of shares prescribed in Article 291, paragraph (1), item (iv) of the New Order that a Nonresident prescribed in Article 164, paragraph (1), item (iv) (Method of Taxation of Nonresidents) of the New Act makes on or after the Effective Date of the Trust Act, and the provisions then in force continue to govern income from the transfer of shares or beneficial interests prescribed in Article 291, paragraph (1), item (iv) (Taxable Income of Nonresidents Without a Permanent Establishment) of the Former Order that was made before the Effective Date of the Trust Act. In this case, if the date specified in Article 1, item (vi) (Effective Date) of the Supplementary Provisions falls after the Effective Date of the Trust Act, with regard to the application of Article 291, paragraph (1), item (iv) of the New Order during the period from the Effective Date of the Trust Act until the day before the date specified in Article 1, item (vi) of the Supplementary Provisions, the phrase "Article 2, paragraph (14)" in that item is deemed to be replaced with "Article 2, paragraph (21)".

②The provisions of Article 291, paragraph (7) of the New Order apply to cases where a company split by split-off listed in item (i), (a) or (b) of that paragraph occurs on or after May 1, 2007, and the provisions then in force continue to govern cases where a company split by split-off listed in Article 291, paragraph (7), item (i), (a) or (b) of the Former Order occurred before that date.