Article 321-8, paragraph (3)

With regardrespect to a corporation that is obliged to file a under an obligation to file a return concerning corporation tax return pursuant to the provisions of Article 71, paragraph (1) of the Corporation Tax Act (limited to the case where Article 72, paragraph (1) of that Act applies) or Article 74, paragraph (1) of that Act, where there is a deficit before application of group tax sharing arising in a business year that began within 10 years before the start of the business year concerned (meaning an amount of loss under(meaning a deficit prescribed in Article 57, paragraph (1) of that Act (excluding one deemed not to existtreated as non-existent pursuant to Article 58, paragraph (1) of that Act) that is deemed not to existtreated as non-existent pursuant to Article 57, paragraph (6) or (8) of that Act; the same applies in paragraphs (4) through (6)), the following paragraph through paragraph (6)) arising in a business year that began within 10 years before the start date of the business year in question, then, for the calculation of the corporation tax amount that serves asis the tax base of the corporation tax levy for thethat business year concerned to be paid by that the corporation is to be madepay, notwithstanding paragraph (1), (34) or (35), by deducting the deductible pre-group-taxation loss adjustment amount adjustment amount for deficit before application of group tax sharing is to be deducted from the corporation tax amount serving asthat is the tax base of the corporation tax levy for the computation period of the tax base of thatthe corporation tax amount to be filed and paid pursuant to paid through filing and payment under those provisions, up to the amountlimit of that corporation tax amount (where there is an amount has been added to that corporation tax amount pursuant to Article 42-14, paragraph (1) or (4), Article 62, paragraph (1), Article 62-3, paragraph (1) or (9)(10), or Article 63, paragraph (1) of the Act on Special Measures Concerning Taxation, the amount remaining after deductingafter subtracting the amount specified by Cabinet Order). In this case, the deductible pre-group-taxation loss adjustment amount adjustment amount for deficit before application of group tax sharing is limited to the amount that wascould not be deducted from the corporation tax amount to serve as that is to be the tax base of the corporation tax levy for the previous business year andor earlier business years.