in the case where a Foreign Corporation that did not have a former permanent establishment (meaning a Foreign Corporation that did not have a former permanent establishment as of December 31, 2018 but had something falling under a new permanent establishment; the same applies hereinafter in this paragraph) came to have a new permanent establishment on January 1, 2019, interest on bonds issued before that date by that Foreign Corporation that did not have a former permanent establishment which relates to business conducted through that new permanent establishment is deemed not to fall under domestic source income set forth in Article 161, paragraph (1), item (viii) of the Income Tax Act;