Supplementary Provisions, Article 3, paragraph (4), item (ii)
二
in the case where a Foreign Corporation that did not have a former permanent establishment came to have a new permanent establishment on January 1, 2019, the provisions of Article 6, paragraphs (1) through (3) of the Act on Special Measures Concerning Taxation do not apply to bonds issued outside Japan before that date by that Foreign Corporation that did not have a former permanent establishment (limited to those specified by Cabinet Order as relating to business conducted through that new permanent establishment), the interest on which is paid outside Japan;