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, those of the redemption gains (meaning redemption gains as prescribed in Article 41-13-2, paragraph (1) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this item) on discount bonds (meaning discount bonds as prescribed in that paragraph; the same applies hereinafter in this item) issued before that date by that Foreign Corporation that did not have a former permanent establishment which are specified by Cabinet Order as relating to business conducted through that new permanent establishment are deemed not to fall under the redemption gains on discount bonds that are deemed to be domestic source income set forth in Article 161, paragraph (1), item (ii) of the Income Tax Act pursuant to the provisions of that paragraph.