Article 15Priority of Pledges Established on or before the Statutory Due Date for Tax Payment, etc.

一National tax (including negligence tax) whose payable amount has been determined after the statutory due date for tax payment: the day on which the written notice of reassessment, written notice of determination or written notice of tax payment therefor was issued (for national tax under the self-assessment system that has been determined by a return, the day on which the return was filed);

二National tax for which a demand under Article 38, paragraph (1) (Advance Demand) of the Act on General Rules for National Taxes (hereinafter referred to as an "advance demand") was made before the statutory due date for tax payment: the due date pertaining to that demand;

三Income tax for the second period (meaning income tax payable in the second period prescribed in Article 104, paragraph (1) (Making Tax Prepayments) of the Income Tax Act (including where applied mutatis mutandis pursuant to Article 166 (Filing of Returns, Payment of Taxes, and Issuance of Refunds) of that Act; the same applies hereinafter in this item) under the provisions of that paragraph, and including income tax payable under the provisions of Article 115 (Special Provisions on the Deadlines for Making Tax Prepayments If the Taxpayer Will Become Absent From Japan) of that Act (including where applied mutatis mutandis pursuant to Article 166 of that Act) that is to be paid after the due date for payment of the income tax payable in the first period prescribed in Article 104, paragraph (1) of that Act): the due date for payment of the income tax payable in that first period;

四Inheritance tax or gift tax for which the payable tax amount has been determined by reassessment or determination under Article 35, paragraph (2) (Special Provisions on Reassessment and Determination) of the Inheritance Tax Act: the day on which the written notice of reassessment or written notice of determination therefor was issued;

四の二Land value tax (excluding that paid by the statutory tax return due date prescribed in Article 2, item (vii) (Definitions) of the Act on General Rules for National Taxes (hereinafter in this item referred to as the "statutory tax return due date") and that listed in item (i)): the day on which the written notice of reassessment or written notice of determination therefor was issued (for that determined by a return, the day on which the return was filed (if that day is before the statutory tax return due date for the land value tax, that statutory tax return due date));

五Revaluation tax whose determined tax amount is paid in two or more payment periods, and which is paid in a payment period after the first: the first due date for payment of that revaluation tax;

五の二National tax listed in Article 15, paragraph (3), items (ii) through (iv) and item (vi) (Establishment of Tax Liability and Determination of the Payable Tax Amount) of the Act on General Rules for National Taxes (excluding that paid on or before the statutory due date for tax payment): the day on which the written notice of tax payment therefor was issued (for national tax paid after the statutory due date for tax payment without receiving notice of tax payment, the day on which the payment was made);

六National tax of which notice was given or which was notified under Article 24, paragraph (2) (Liability in Rem for Tax of a Holder of Property Transferred as Security) or Article 159, paragraph (3) (Preservative Seizure) (including where applied mutatis mutandis pursuant to Article 38, paragraph (4) of the Act on General Rules for National Taxes): the day on which the written notice or notification under those provisions was issued;

七National tax of a decedent (including a person who has made a comprehensive testamentary gift; the same applies hereinafter) collected from the heir's own property (including a comprehensive legatee; the same applies hereinafter), and the heir's own national tax collected from the inherited property (limited to those for which the payable tax amount was determined before the day on which the inheritance (including a comprehensive testamentary gift; the same applies hereinafter) occurred (for national taxes listed in Article 15, paragraph (3), items (ii) through (iv) and item (vi) of the Act on General Rules for National Taxes, those for which the written notice of tax payment was issued before that day; the same applies hereinafter in this paragraph)): the day on which the inheritance occurred;

八The own national tax of the corporation surviving after a merger or of another merged corporation pertaining to that merger, collected from the property that belonged to a corporation that ceased to exist by the merger (hereinafter referred to as a "merged corporation"), and the national tax of a merged corporation collected from the property of the corporation surviving after the merger (limited to those for which the payable tax amount was determined before the day of the merger): the day of the merger;

九The own national tax of the splitting corporation collected from the property that has come to belong to the corporation that made the split (hereinafter in this item referred to as the "splitting corporation") upon finalization of a judgment invalidating that split, and the national tax of the splitting corporation pertaining to the obligation to pay jointly and severally prescribed in Article 9-2 (Joint and Several Obligation to Pay upon a Judgment Invalidating a Merger, etc. of a Corporation) of the Act on General Rules for National Taxes, collected from the splitting corporation's own property (limited to those for which the payable tax amount was determined before the day on which the judgment became final): the day on which the judgment became final;

十The own national tax of the successor corporation in a company split (meaning a corporation that succeeded to a business by a split; hereinafter in this item referred to as the "successor corporation in a company split") collected from the property it succeeded from the corporation that made that split (hereinafter in this item referred to as "succeeded property"), the national tax pertaining to the successor corporation in a company split's joint and several liability for payment prescribed in Article 9-3 (Joint and Several Liability for Payment Related to a Corporate Split) of the Act on General Rules for National Taxes (hereinafter in this item referred to as "joint and several liability for payment") collected from the own property of the successor corporation in a company split, and the national tax of another corporation that made a split pertaining to that split, which pertains to the successor corporation in a company split's joint and several liability for payment, collected from the succeeded property of the successor corporation in a company split (limited to those for which the payable tax amount was determined before the day of the split): the day of the split; and

十一National tax payable as a secondary taxpayer or guarantor: the day on which the written payment notice under Article 32, paragraph (1) (General Rules on Secondary Tax Liability) or Article 52, paragraph (2) (Disposition of the Collateral and Enforcement of Guarantee) of the Act on General Rules for National Taxes was issued.

一Notarized deed;

二A private document bearing a dated seal affixed at a registry office or notary's office;

三A document for which certification of contents has been received under Article 48, paragraph (1) (Certification of Contents) of the Postal Act (Act No. 165 of 1947);

四A document delivered under Article 60, paragraph (4) (Preservation, etc. of Information Sufficient to Confirm the Identity of Information Recorded in Certified Electromagnetic Records) of the Notary Act (Act No. 53 of 1908) as applied mutatis mutandis pursuant to Article 7, paragraph (1) (Application Mutatis Mutandis of the Provisions of the Notary Act) of the Act for Enforcement of the Civil Code (Act No. 11 of 1898).