Article 53, paragraph (23), item (ii)

a foreign corporation that has received a refund, pursuant to Article 144-13 of the Corporation Tax Act, of of the corporation tax amount on the domestic source income listed set forth in Article 141, item (i), (a) of that Act: the refunded corporation tax amount (hereinafter in this paragraph through paragraph (25) referred to as the "deductible refunded corporation tax on a foreign corporation's income attributable to a permanent establishment") is to be deductedthe Corporation Tax Act pursuant to Article 144-13 of that Act: from the corporation tax amount on the domestic source income listed set forth in (a) of that item that is to be the tax base of the corporation tax levy to be filed and paidpaid through filing and payment under paragraph (1), (34) or (35), the refunded corporation tax amount (hereinafter in this paragraph through paragraph (25) referred to as "deductible refunded corporation tax on a foreign corporation's income attributable to a permanent establishment") is to be deducted, up to the limit of that corporation tax amount (or, if there is an amount added with respectwhere an amount has been added to that corporation tax amount pursuant to 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 after deductingsubtracting the amount specified by Cabinet Order). In this case, the deductible refunded corporation tax on a foreign corporation's income attributable to a permanent establishment is limited to the amount that hascould not beenbe deducted from the corporation tax amount that is to be the tax base of the corporation tax levy for the previous business year or earlier;