Article 176Special Provisions on Taxation of Interest and Similar Income from Trust Property

①If a trust company that is a Domestic Corporation (this includes a financial institution as prescribed in Article 1, paragraph (1) (Approval for Additional Business) of the Act on Engagement in Trust Business Activities by Financial Institutions which is engaged in trust business as prescribed in that paragraph; referred to as a "domestic trust company" in the following paragraph) has an entry made in the books kept by a person paying interest and similar income as prescribed in Article 23, paragraph (1) (Interest Income) (hereinafter referred to as "interest and similar income" in this Article) or dividends and similar income as prescribed in Article 24, paragraph (1) (Dividend Income) (hereinafter referred to as "dividends and similar income" in this Article) in Japan, indicating that the Public and Corporate bonds constituting a part of the trust property of a Securities Investment Trust (limited to one established as a trust at a business office in Japan) of which the trust company has undertaken to act as trustee; or a beneficial interest, company bond-type beneficial interest, share, or capital contribution under a Jointly Managed Trust, Investment Trust, or Specified Trust That Issues Beneficiary Certificates (hereinafter referred to as a "public and corporate bond or similar interest" in this paragraph) is a part of the trust property, or if the trust company has a record made of any other information prescribed by Ministry of Finance Order, the provisions of Article 7, paragraph (1), item (iv) (Scope of Taxable Income of Domestic Corporations) and the preceding two Articles do not apply to interest and similar income or dividends and similar income that are paid during the time that such information on the public and corporate bond or similar interest remains on the books.

③The income taxes paid by a Domestic Corporation on the trust property of a group investment trust as prescribed in Article 13, paragraph (3), item (i) (limited to one established as a trust at a business office located in Japan; hereinafter referred to as a "group investment trust" in this Article) of which the corporation has undertaken to act as trustee (limited to the part corresponding to income taxes that would be required to be withheld on the distribution of proceeds pursuant to Article 181 (Obligation to Withhold Taxes) or Article 212 (Obligation to Withhold Taxes) if the proceeds on which those income taxes were imposed were distributed (excluding the part corresponding only to what is set forth in Article 9, paragraph (1), item (xi) (Nontaxable Income)), and including any taxes equivalent to income taxes and prescribed by Cabinet Order which are imposed pursuant to foreign laws or orders; the same applies in the following paragraph) are credited against the income taxes on distributions of proceeds from that group investment trust, pursuant to Cabinet Order.

④The income taxes paid on the trust property of a group investment trust which are to be credited pursuant to the preceding paragraph are added to the amount of distributions of proceeds from the investment trust when those distributions of proceeds are calculated.

⑤Beyond what is prescribed in the preceding paragraph, Cabinet Order provides for particulars concerning the notice that the Domestic Corporation referred to in paragraph (3) gives to a person paid distributions of proceeds from a group investment trust, particulars concerning the amount of tax withheld as prescribed in Article 120, paragraph (1), item (iv) (Filing an Income Tax Return) which that person deducts from the income tax set forth in item (iii) of that paragraph and states in a return under that paragraph, and other necessary particulars concerning the application of the provisions of paragraph (3).