①The income taxes imposed on a Nonresident are calculated by applying the provisions of Subsection 1 of the following Section (Taxing Nonresidents on Aggregate Income) to the domestic source income that is specified in each of the following items for the category of Nonresident set forth in the item:

②If a Nonresident set forth in either of the following items has domestic source income as specified in that item, the income taxes imposed on the Nonresident are calculated by applying the provisions of Section 3 (Separate Assessment of Income Tax for Nonresidents) to the domestic source income specified in the relevant item, in addition to what is imposed pursuant to the preceding paragraph:

①The tax base and the amount of income taxes imposed on the domestic source income, as specified in the relevant of the items of paragraph (1) of the preceding Article, of the Nonresident set forth in the relevant item (hereinafter referred to as "Income Taxes Imposed on Aggregate Income" in this Section) are the amounts calculated against the domestic source income specified in the relevant item, unless otherwise provided, in accordance with the provisions of Part II, Chapter I through Chapter IV (Calculation of the Tax Base and Amount of Income Taxes for Residents) (excluding Article 44-3 (Exclusion of Reduced Foreign Income Taxes from Gross Revenue), Article 46 (Exclusion of Foreign Taxes Credited against Income Taxes from Necessary Expenses), Article 60-4 (Special Provisions on Capital Gains upon Application of the Provisions on Taxation at the Time of Departure from Japan), Article 73 through 77 (Medical Expense Deduction), Article 79 through 85 (Disability Deduction), Article 93 (Credit for Amount Equivalent to Foreign Tax Adjusted at Distribution), Article 95 (Foreign Tax Credit), and Article 95-2 (Special Provisions on Foreign Tax Credit Related to Special Provisions on Capital Gains upon Departure from Japan)).

②If Income in Each Class related to the domestic source income set forth in item (i), (a) of paragraph (1) of the preceding Article of the Nonresident set forth in that item (hereinafter referred to as "income attributable to a permanent establishment" in this Subsection) is calculated in accordance with the provisions of Part II, Chapter II, Section 2, Subsection 1 and Subsection 2 (Calculation of Income in Each Class) pursuant to the preceding paragraph, the following applies:

③Beyond what is prescribed in the preceding paragraph, Cabinet Order provides for the necessary particulars concerning the application of the provisions of paragraph (1).

If a reduction is made to the amount of foreign income taxes as prescribed in Article 165-6, paragraph (1) which is used as the basis for calculating the amount to be credited pursuant to the provisions of Article 165-6, paragraphs (1) through (3) (Foreign Tax Credit for Nonresidents) in any of the seven years beginning in the year after that in which a Nonresident is subject to the provisions of those paragraphs, the amount that Cabinet Order prescribes as corresponding to the part of the reduction to foreign income taxes which is pertinent to the application of the credit under paragraphs (1) through (3) of that Article in the year in which the date of the decision to reduce those taxes falls is not included in gross revenue that is used to calculate the Nonresident's real property income, business income, timber income, occasional income, or miscellaneous income for the year, calculated in accordance with paragraph (1) of the preceding Article with regard to the Nonresident's income attributable to a permanent establishment. In such a case, the amount arrived at when the amount specified by that Cabinet Order is deducted from the amount of the reduction is included in the gross revenue that is used to calculate the Nonresident's miscellaneous income for the year, calculated in accordance with that paragraph.

①If the amount calculated pursuant to Cabinet Order as the amount of net assets pertaining to the permanent establishment of a Nonresident for each year is less than the amount calculated pursuant to Cabinet Order as the amount that should be attributed to the permanent establishment out of the amount equivalent to the amount of net assets of the Nonresident, the amount calculated pursuant to Cabinet Order as the part corresponding to the shortfall, out of the amount prescribed by Cabinet Order as the amount of interest on liabilities (including anything prescribed by Cabinet Order as equivalent thereto) related to the business conducted by the Nonresident through the permanent establishment in that year, is not included in necessary expenses or the amount expended in calculating the Nonresident's real property income, business income, timber income, or miscellaneous income, or occasional income for that year, calculated in accordance with Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the Nonresident's income attributable to a permanent establishment for that year.

②Cabinet Order provides for the necessary particulars concerning the application of the provisions of the preceding paragraph.

If, with regard to the amount of credit-eligible foreign income tax prescribed in Article 165-6, paragraph (1) (Foreign Tax Credit for Nonresidents), a Nonresident is subject to the provisions of that Article or of Article 138, paragraph (1) (Refunding Tax Withheld) as applied mutatis mutandis pursuant to Article 166 (Filing of Returns, Payment of Taxes, and Issuance of Refunds), that amount of credit-eligible foreign income tax is not included in necessary expenses or the amount spent in calculating the Nonresident's real property income, business income, timber income, or miscellaneous income, or occasional income, calculated in accordance with Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the Nonresident's income attributable to a permanent establishment.

①If a Nonresident is subject to the provisions of Article 165, paragraph (2), item (ii) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income), and documents used as the basis for calculating the allocation and other documents prescribed by Ministry of Finance Order are not retained with regard to the amount allocated pursuant to Cabinet Order as prescribed in that item (hereinafter referred to as "allocated expenses" in this Article), the allocated expenses for which those documents were not retained are not included in necessary expenses or the amount expended in calculating the Nonresident's real property income, business income, timber income, or miscellaneous income, or occasional income for each year, calculated in accordance with Article 165, paragraph (1) with regard to the Nonresident's income attributable to a permanent establishment for that year.

②Even if the documents referred to in the preceding paragraph have not been retained with regard to all or part of the allocated expenses, the district director may decide not to apply the provisions of that paragraph to the allocated expenses for which those documents were not retained, if the district director finds that there were unavoidable circumstances for the failure to retain them, but only if those documents are submitted.

①If there has been, between the permanent establishment of a Nonresident and a place of business or similar place as prescribed in Article 161, paragraph (1), item (i) (Domestic Source Income), an internal dealing (meaning an internal dealing as prescribed in item (i) of that paragraph; hereinafter the same applies in this paragraph) equivalent to the acquisition or transfer by the permanent establishment of assets that would generate domestic source income set forth in item (iii), item (v), or item (vii) of that paragraph (other than that prescribed by Cabinet Order), the internal dealing is deemed to have been conducted at the amount prescribed by Cabinet Order as the value of those assets immediately before the internal dealing, and the Nonresident's real property income, business income, timber income, capital gains, or miscellaneous income is calculated in accordance with the provisions of Part II, Chapter I and Chapter II (Calculation of the Tax Base for Income Taxes for Residents) pursuant to Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the Nonresident's income attributable to a permanent establishment for each year.

②Cabinet Order provides for the acquisition cost of assets at the permanent establishment of a Nonresident if the provisions of the preceding paragraph apply, and for other necessary particulars concerning the application of the provisions of that paragraph.

①If a Nonresident with a permanent establishment is paid a distribution of proceeds from a group Investment Trust as prescribed in Article 176, paragraph (3) (Special Provisions on Taxation of Interest and Similar Income from Trust Property) in any year (limited to where the Nonresident is paid a distribution that falls under income attributable to a permanent establishment), the amount equivalent to the amount prescribed by Cabinet Order as the part corresponding to the distribution of proceeds that the Nonresident is paid, out of the amount of foreign tax adjusted at distribution related to that distribution of proceeds (meaning a tax prescribed by Cabinet Order which is equivalent to income tax imposed pursuant to foreign laws or orders as prescribed in that paragraph) which has been credited against the income tax on that distribution of proceeds pursuant to that paragraph or Article 180-2, paragraph (3) (Special Provisions on Taxation of Interest and Similar Income from Trust Property) (referred to as the "amount equivalent to the foreign tax adjusted at distribution" in the following paragraph), is credited against the income tax for that year, up to the maximum credit (meaning the amount prescribed by Cabinet Order as the amount equivalent to the income tax for that year calculated in accordance with the provisions of Article 89 through Article 92 (Tax Rates and Dividend Tax Credits) pursuant to Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the income related to income attributable to a permanent establishment).

②The provisions of Article 93, paragraph (2) (Credit for the Amount Equivalent to Foreign Tax Adjusted at the Time of Distribution) apply mutatis mutandis where a credit is made under the preceding paragraph with regard to the amount equivalent to the foreign tax adjusted at distribution.

③The amount to be credited pursuant to paragraph (1) is credited against the income tax on taxable total income, the income tax on taxable timber income, and the income tax on taxable retirement income calculated in accordance with Article 165, paragraph (1), in that order. In such a case, if the amount to be credited exceeds the income tax for the year, the amount to be credited is the amount equivalent to that income tax.

④Beyond what is prescribed in the preceding two paragraphs, Cabinet Order provides for the necessary particulars concerning the application of the provisions of paragraph (1).

①If a Nonresident with a permanent establishment has to pay foreign income taxes (meaning foreign income taxes as prescribed in Article 95, paragraph (1) (Foreign Tax Credit); hereinafter the same applies in this paragraph and paragraph (6)) in any year, the amount of those foreign income taxes (limited to the amount of foreign income taxes imposed on domestic source income set forth in Article 161, paragraph (1), item (i) (Domestic Source Income), and excluding the amount of any foreign income taxes imposed on income arising from a transaction prescribed by Cabinet Order as one that cannot be regarded as an ordinary transaction undertaken by a Nonresident and the amount of any other foreign income taxes prescribed by Cabinet Order; hereinafter referred to as the "amount of credit-eligible foreign income tax" in this Article) is credited against the income tax for that year, up to the amount calculated pursuant to Cabinet Order as corresponding to the amount of foreign income arising in that year (meaning the amount prescribed by Cabinet Order as the part of the income related to income attributable to a permanent establishment which relates to foreign source income), out of the income tax for that year calculated pursuant to the provisions of Article 89 through Article 92 (Tax Rates and Dividend Tax Credits), as applied in accordance with Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) to the income related to income attributable to a permanent establishment, and the provisions of the preceding Article (hereinafter referred to as the "maximum credit" in this Article).

②If the amount of credit-eligible foreign income tax which a Nonresident with a permanent establishment has to pay in any year exceeds the sum total of the maximum credit for the year and the amount specified by Cabinet Order as the maximum credit for local taxes, and part of the maximum credit in any of the three years prior to the relevant year (referred to as "any of the last three years" in the following paragraph) is an amount prescribed by Cabinet Order as being carried over to the relevant year (hereinafter referred to as the "maximum carry-over credit" in this paragraph), the amount by which the former exceeds the latter is credited against the income tax for the year pursuant to Cabinet Order, up to the maximum carry-over credit.

③If the amount of credit-eligible foreign income tax which a Nonresident with a permanent establishment has to pay in any year is less than the maximum credit for the year, and part of the amount of credit-eligible foreign income tax that the Nonresident has had to pay in any of the last three years constitutes an amount prescribed by Cabinet Order as being carried over to the relevant year (hereinafter referred to as "carry-over, credit-eligible foreign income taxes" in this paragraph), the carry-over, credit-eligible foreign income taxes are credited against the income tax for the year pursuant to Cabinet Order, up to the amount remaining when the amount of credit-eligible foreign income tax that the Nonresident has to pay in that year is deducted from the maximum credit.

④The term "foreign source income" as prescribed in paragraph (1) means income set forth in Article 161, paragraph (1), item (i) which falls under any of the following:

⑤Notwithstanding the provisions of the preceding paragraph, if a tax treaty (meaning a treaty as prescribed in the proviso to Article 2, paragraph (1), item (viii)-4; hereinafter the same applies in this paragraph) contains provisions on foreign source income (meaning foreign source income as prescribed in paragraph (1); hereinafter the same applies in this paragraph) which differ from the provisions of the preceding paragraph, the foreign source income of a Nonresident subject to that tax treaty is governed by that tax treaty, to the extent of the differing provisions.

⑥If the foreign income taxes that a Nonresident has had to pay are reduced in any of the seven years beginning in the year after one in which the Nonresident is subject to the provisions of paragraphs (1) through (3) with regard to those foreign income taxes, Cabinet Order provides for the application of those provisions to foreign income taxes for the year in which the day that the amount is reduced falls.

⑦The provisions of Article 95, paragraphs (10) and (11) apply mutatis mutandis where a credit is made under paragraphs (1) through (3) with regard to the amount of credit-eligible foreign income tax that a Nonresident has to pay. In such a case, in paragraph (10) of that Article, the phrase "the provisions of paragraph (1)" is deemed to be replaced with "the provisions of Article 165-6, paragraph (1) (Foreign Tax Credit for Nonresidents)", the phrase "a credit under paragraph (1)" is deemed to be replaced with "a credit under paragraph (1) of that Article", the phrase "the amount of credit-eligible foreign income tax" is deemed to be replaced with "the amount of credit-eligible foreign income tax prescribed in that paragraph (hereinafter referred to as the "amount of credit-eligible foreign income tax" in this paragraph and the following paragraph)", and the phrase "the amount to be credited under paragraph (1)" is deemed to be replaced with "the amount to be credited under paragraph (1) of that Article"; and in paragraph (11) of that Article, the phrase "paragraphs (2) and (3)" is deemed to be replaced with "Article 165-6, paragraphs (2) and (3)", the phrase "the maximum carry-over credit or carry-over, credit-eligible foreign income taxes" is deemed to be replaced with "the maximum carry-over credit prescribed in paragraph (2) of that Article (hereinafter referred to as the "maximum carry-over credit" in this paragraph) or carry-over, credit-eligible foreign income taxes prescribed in paragraph (3) of that Article (hereinafter referred to as "carry-over, credit-eligible foreign income taxes" in this paragraph)", and the phrase "the maximum credit for each of those years in the returns, etc." is deemed to be replaced with "the maximum credit for each of those years (meaning the maximum credit prescribed in paragraph (1) of that Article; hereinafter the same applies in this paragraph) in the returns, etc.".

⑧The amount to be credited under paragraphs (1) through (3) is credited against the income tax on taxable total income, the income tax on taxable timber income, and the income tax on taxable retirement income calculated in accordance with Article 165, paragraph (1), in that order.

⑨Beyond what is prescribed in the preceding three paragraphs, Cabinet Order provides for the necessary particulars concerning the application of the provisions of paragraphs (1) through (5).

The provisions of Part II, Chapter V and Chapter VI (Filing of Returns, Payment of Taxes, and Issuance of Refunds for Residents) apply mutatis mutandis to the filing of returns, payment of taxes, and issuance of refunds for a Nonresident's Income Taxes Imposed on Aggregate Income. In such a case, in Article 112, paragraph (2) (Process of Applying for Approval for a Reduction of Tax Prepayments), the term "transactions" is deemed to be replaced with "transactions (for a Nonresident with a permanent establishment, including those falling under internal dealings as prescribed in Article 161, paragraph (1), item (i) (Domestic Source Income))" and the phrase "that paragraph" is deemed to be replaced with "the preceding paragraph"; in Article 120, paragraph (1) (Filing an Income Tax Return), the phrase "foreign tax credit" is deemed to be replaced with "credit under Article 165-6, paragraphs (1) through (3) (Foreign Tax Credit for Nonresidents)"; in item (iii) of that paragraph, the phrase "Chapter III (Calculation of Tax Amount)" is deemed to be replaced with "Chapter III (excluding Article 93 (Credit for Amount Equivalent to Foreign Tax Adjusted at Distribution) and Article 95 (Foreign Tax Credit)) (Calculation of Tax Amount), and Article 165-5-3 (Credit for Amount Equivalent to Foreign Tax Adjusted at Distribution for Nonresidents) and Article 165-6"; in paragraph (6) of that Article, the phrase "business that generates timber income" is deemed to be replaced with "business that generates timber income (limited to business related to the domestic source income specified in the items of Article 164, paragraph (1) (How Nonresidents Are Taxed); hereinafter referred to as "specified business" in this paragraph)", the phrase "business that generates miscellaneous income" is deemed to be replaced with "specified business that generates miscellaneous income", the phrase "that business" is deemed to be replaced with "that specified business", and the phrase "must be attached to that return" is deemed to be replaced with "must be attached to that return, and if a Nonresident conducting business both in Japan and outside Japan files a return under that paragraph, a detailed statement of revenue and expenditures as prescribed by Ministry of Finance Order must be attached to that return"; in Article 122, paragraph (1), item (i) (Filing a Return to Receive a Refund), the phrase "foreign tax credit" is deemed to be replaced with "credit under Article 165-6, paragraphs (1) through (3) (Foreign Tax Credit for Nonresidents)"; in paragraph (2) of that Article, the phrase "Article 95, paragraph (2) or (3) (Foreign Tax Credit)" is deemed to be replaced with "Article 165-6, paragraph (2) or (3)"; in Article 123, paragraph (2), item (vi) (Filing Tax Returns Showing Losses), the phrase "Article 95 (Foreign Tax Credit)" is deemed to be replaced with "Article 165-6 (Foreign Tax Credit for Nonresidents)"; in Article 143 (Blue Returns), the term "business" is deemed to be replaced with "business (limited to business related to the domestic source income specified in the items of Article 164, paragraph (1) (How Nonresidents Are Taxed))"; in Article 144 (Application for Approval to File a Blue Return), the phrase "commences business" is deemed to be replaced with "commences business (limited to business related to the domestic source income specified in the items of Article 164, paragraph (1) (How Nonresidents Are Taxed))"; in Article 145, item (ii) (Denial of Applications for Approval to File a Blue Return), the term "transactions" is deemed to be replaced with "transactions (for a Nonresident with a permanent establishment, including those falling under internal dealings as prescribed in Article 161, paragraph (1), item (i) (Domestic Source Income); the same applies in Article 148, paragraph (1) and Article 150, paragraph (1), item (iii) (Rescission of Approval to File a Blue Return))"; and in Article 147 (When a Resident Is Deemed to Receive Approval to File a Blue Return), the term "business" is deemed to be replaced with "business (limited to business related to the domestic source income specified in the items of Article 164, paragraph (1) (How Nonresidents Are Taxed))".

①If a Nonresident with a permanent establishment has domestic source income set forth in Article 161, paragraph (1), item (i) (Domestic Source Income) (hereinafter referred to as "income attributable to a permanent establishment" in this Article), the Nonresident must, pursuant to Ministry of Finance Order, prepare documents giving the details of the transactions attributed to the permanent establishment and other documents prescribed by Ministry of Finance Order with regard to any transaction that the Nonresident has conducted with another person the income from which is attributed to the permanent establishment of the Nonresident in calculating Income in Each Class calculated in accordance with Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the Nonresident's income attributable to a permanent establishment for that year.

②If a Nonresident with a permanent establishment has income attributable to a permanent establishment, and a transfer of assets, provision of services, or other fact between the Nonresident's place of business or similar place as prescribed in Article 161, paragraph (1), item (i) and the permanent establishment falls under an internal dealing as prescribed in that item, the Nonresident must, pursuant to Ministry of Finance Order, prepare documents giving the details of that fact and other documents prescribed by Ministry of Finance Order.

The provisions of Part II, Chapter VII (Special Provisions on Residents' Requests for Reassessment) apply mutatis mutandis to a request for Reassessment pursuant to the provisions of Article 23, paragraph (1) of the Act on General Rules for National Taxes (Requests for Reassessment) involving a Nonresident's Income Taxes Imposed on Aggregate Income.

The provisions of Part II, Chapter VIII (Reassessments and Determinations Involving Residents) apply mutatis mutandis to Reassessments and determinations involving a Nonresident's Income Taxes Imposed on Aggregate Income.

If there is an act or calculation of a Nonresident who has domestic source income set forth in Article 164, paragraph (1), item (i), (a) (How Nonresidents Are Taxed) which, if allowed, would be found to result in an unjust reduction of the Nonresident's income tax burden due to an increase in the amount deducted in calculating Income in Each Class related to that domestic source income, an increase in the amount deducted from the income tax on the income related to that domestic source income, a decrease in the amount of profit or an increase in the amount of loss related to internal dealings as prescribed in Article 161, paragraph (1), item (i) (Domestic Source Income), or any other reason, the district director may, when making a Reassessment or determination concerning the Nonresident's income tax, calculate the amounts set forth in Article 120, paragraph (1), item (i) or items (iii) through (v) (Filing an Income Tax Return), Article 122, paragraph (1), items (i) through (iii) (Filing a Return to Receive a Refund), or Article 123, paragraph (2), item (i), item (iii), item (v), or item (vii) (Filing Tax Returns Showing Losses), as applied mutatis mutandis pursuant to Article 166 (Filing of Returns, Payment of Taxes, and Issuance of Refunds), for each year of the Nonresident, as the district director finds appropriate, notwithstanding that act or calculation.

Income taxes are imposed on a Nonresident's domestic source income as set forth in the items of Article 164, paragraph (2) (How Nonresidents Are Taxed), separately from the Nonresident's other income, and the tax base for those income taxes is the amount constituting the domestic source income that the Nonresident is to be paid (or, for domestic source income as set forth in one of the following items, the amount prescribed in the item):

The income taxes prescribed in the preceding Article constitute the amount calculated when the domestic source income prescribed in that Article is multiplied by a tax rate of 20 percent (or by a tax rate of 15 percent, for domestic source income as set forth in Article 161, paragraph (1), item (viii) and item (xv) (Domestic Source Income)).

Notwithstanding the preceding Article, if a Nonresident as prescribed in Article 169 (Tax Base) is paid severance pay or other such compensation (meaning severance pay or other such compensation as prescribed in Article 30, paragraph (1) (Retirement Income); hereinafter the same applies in this Section) that falls under the provisions of Article 161, paragraph (1), item (xii), (c) (Domestic Source Income), the Nonresident may elect to have it deemed that the total amount of the severance pay and other such compensation that the Nonresident is paid in that year by reason of a separation from employment constituting a cause for its payment (or by reason of each separation from employment constituting a cause for payment, if the Nonresident is paid multiple packages of severance pay or other such compensation in the relevant year) has been paid thereto as if to a Resident, and to have income taxes imposed on the severance pay and other such compensation in line with the amount equivalent to taxes imposed when Article 30 and Article 89 (Tax Rates) are applied to the total amount of severance pay and other such compensation that the Nonresident is deemed to have received as a Resident.

①If a Nonresident as prescribed in Article 169 (Tax Base) is paid a salary or remuneration as set forth in Article 161, paragraph (1), item (xii), (a) or (c) (Domestic Source Income), and the provisions of Part IV, Chapter V (Withholding from the Income of Nonresidents and Corporations) do not apply to that salary or remuneration, unless the Nonresident may file a return under the following Article, the Nonresident must file a return with the district director no later than March 15 of the following year (or by the day on which the Nonresident ceases to have a residence in Japan, if this is the case), giving the following information:

②If a Nonresident that must file a return under the preceding paragraph for severance pay or other such compensation as prescribed in the preceding Article elects to have that severance pay or other such compensation taxed as referred to in that Article, the Nonresident must give the following information in the return, in addition to the information set forth in the items of that paragraph:

③A Nonresident filing a return under paragraph (1) must pay income taxes to the national government in an amount equivalent to what is set forth in item (iii) of that paragraph (or in an amount equivalent to what is set forth in item (iii) of that paragraph and item (iii) of the preceding paragraph, if the Nonresident is subject to the provisions of the preceding paragraph), by the deadline for filing the return.

①If a Nonresident prescribed in Article 169 (Tax Base) is subject to Part IV, Chapter V (Withholding from the Income of Nonresidents and Corporations), as regards severance pay or other such compensation as prescribed in Article 171 (Elective Treatment for Taxation of Retirement Income) that is paid thereto and elects to have that severance pay or other such compensation taxed as referred to in that Article, the Nonresident may file a return with the district tax office director on or after January 1 of the following year (or on or after the day that the total amount of the severance pay and other such compensation as prescribed in Article 171 becomes fixed, if this is before January 1 of the following year), giving the following information, so as to be issued an income tax refund for that severance pay or other such compensation:

②When a return under the preceding paragraph is filed, the district tax office director issues an income tax refund in an amount equivalent to what is set forth in item (iii) of that paragraph.

③In a case as referred to in the preceding paragraph, if any part of the income taxes set forth in paragraph (1), item (ii) which are indicated in the return referred to in the preceding paragraph (limited to income taxes that are required to be withheld pursuant to the provisions of Part IV, Chapter V) has not yet been paid over to the national government, an amount equivalent to the part of the refund under the preceding paragraph which is from income taxes not yet paid over is not refunded until those income taxes are paid over.

④When the amount of Interest on a refund under paragraph (2) is calculated, the period referred to in Article 58, paragraph (1) of the Act on General Rules for National Taxes (Interest on Refunds) which serves as the basis for the calculation is the period beginning on the day after that on which the return is filed pursuant to the provisions of paragraph (1) (or beginning on the day after that on which any income taxes which are subject to a refund as prescribed in the preceding paragraph are paid, if this is after the date on which the return is filed) and ending on the day on which the tax-office decision to pay the refund is reached or on the day on which the refund is Appropriated to cover a required tax payment (or ending on the day on which the refund first could have been Appropriated, if this is before the date of the Appropriation).

⑤Beyond what is prescribed in the preceding two paragraphs, Cabinet Order provides for the procedures for issuing a refund as referred to in paragraph (2) and for other necessary particulars concerning the application of the provisions of that paragraph.