Act on Special Measures Concerning Taxation

a securities investment trust other than a bond investment trust for which the public offering of beneficial rights at its establishment was conducted through a public offering (meaning a public offering as prescribed in Article 9-3, item (ii); the same applies in the following item) (excluding a specified stock investment trust);

a specified an investment trust prescribed in Article 2, paragraph (3) of the Act on Investment Trusts and Investment Corporations listed in Article 2, item (xxix), (b)(2) of the Corporation Tax Act (excluding one that falls under a securities investment trust or a bond-based investment trust under public offering), and a foreign investment trust prescribed in Article 2, paragraph (24) of the Act on Investment Trusts and Investment Corporations that issues beneficiary certificatesis similar thereto, for which the public offering of beneficial rights at its establishment was conducted through a public offering.

a specified trust that issues beneficiary certificates.

transfer of land, etc. to an individual or a corporation that is to carry out the development of a unit of residential land for use in residential construction (limited to that which meets the following requirements) after obtaining permission under Article 29, paragraph (1) of the City Planning Act (limited to permission pertaining to development activities prescribed in Article 4, paragraph (12) of that Act that are carried out within a district specified by Cabinet Order within a city planning district prescribed in paragraph (2) of that Article; hereinafter referred to in this item as a "development permit") (in the case where this status has been succeeded to based on the development permit prescribed in Article 44 or Article 45 of that Act, such individual is to be the individual who was the transferor in the succession who was to carry out the development or an individual who has succeeded to the status; the same applies in paragraph (56)) (in the case where this status has been succeeded to based on the development permit prescribed in Article 44 or Article 45 of the Act, such corporation is to be the corporation that was the transferor in the succession that was to carry out the development or the corporation that has succeeded to that status; the same applies in paragraph (56)), with the transferred land, etc. being used for the unit of residential land (excluding that which falls under the category of a transfer listed in items (vii) through (ix)):

in cases where permission under Article 29, paragraph (1) of the City Planning Act is not required for development of a unit of residential land, the transfer of land, etc. to an individual or a corporation that is to carry out the development of the unit of residential land for use in residential construction (limited to that which meets the following requirements) (in the case where an heir or universal legatee has succeeded to the project for the development due to the death of the individual who was carrying out the development, and where the heir or universal legatee then carries out the development, such individual is to be the deceased individual who was to carry out the development or the heir or universal legatee; the same applies in paragraph (56)) (in the case where the corporation carrying out the development has extinguished as a result of a merger and the merging corporation prescribed in Article 2, item (xii) of the Corporation Tax Act that was involved in the merger has succeeded to the project for the development and carries out the development, such corporation is to be the extinguished corporation that was to carry out the development or the merging corporation; and in the case where the corporation carrying out the development has been split off and the succeedingsuccessor corporation in thea company split prescribed in item (xii)-3 of that Article that was involved in the company split has succeeded to the project for the development and carries out the development, such corporation is to be the split-off corporation that was to carry out the development or the succeedingsuccessor corporation in thea company split; the same applies in paragraph (56)), with the transferred land, etc. being used for the unit of residential land (excluding that which falls under the category of a transfer listed in items (vii) through (ix) or a transfer of land, etc. specified by Cabinet Order):

transfer of land, etc. to an individual or a corporation that is to construct a group of houses or mid-to-high-rise fire-proof apartment houses (limited to that which meets the following requirements) (in the case where an heir or universal legatee has succeeded to the project for the construction due to the death of the individual carrying out the development, and where the heir or universal legatee then carries out the construction, such individual is to be the deceased individual who was to carry out the construction or the heir or universal legatee; the same applies in the following item and paragraph (56)) (in the case where the corporation carrying out the construction has extinguished as a result of a merger and the merging corporation prescribed in Article 2, item (xii) of the Corporation Tax Act that was involved in the merger has succeeded to the project for the construction and carries out the construction, such corporation is to be the extinguished corporation that was to carry out the construction or the merging corporation; and in the case where the corporation carrying out the construction has been split off and the successor corporation in the company split prescribed in item (xii)-3 of that Article that was involved in the company split has succeeded to the project for the construction and carries out the construction, such corporation is to be the split-off corporation that was to carry out the construction or the successor corporation in the company split; the same applies in the following item and that paragraph), with the transferred land, etc. being used for constructing the group of houses or mid-to-high-rise fire-proof apartment houses (excluding that which falls under the category of a transfer listed in items (vii) through (ix), item (x), or the preceding two items):

The provisions of paragraph (1) apply mutatis mutandis where an individual, during the period from October 1, 1987 to December 31, 2028, transfers land, etc. that the individual owns and whose holding period prescribed in paragraph (2) of the preceding Article exceeds five years as of January 1 of the year of the transfer, if the transfer falls under a transfer for a determined site for constructing a superior residential area, etc. (meaning a transfer that has been certified, pursuant to the provisions of Order of the Ministry of Finance, as being found certain to come to fall under a transfer of land, etc. listed in items (xiii) through (xvi) of the preceding paragraph within the period from the date of the transfer until December 31 of the year that includes the day on which two years have elapsed from that date (where there are unavoidable circumstances specified by Cabinet Order, such as that the period required for the development of residential land for use in residential construction normally exceeds two years, the period from the date of the transfer until the date specified by Cabinet Order; referred to as the "scheduled period" in paragraph (56)); the same applies in paragraph (89)). In this case, the phrase "transfer for a superior residential area, etc." in paragraph (1) is deemed to be replaced with "transfer for a determined site for constructing a superior residential area, etc. prescribed in paragraph (3)".

An In the case referred to in paragraph (1) (including as applied mutatis mutandis pursuant to paragraph (3)), if an individual or a corporationhas made a transfer that carries out the development referred to falls under a transfer of land, etc. listed in paragraph (2), itemitems (xiii) or item (xiv) orthrough (xv), and the construction referred to in item (xv) or item (xvitransferred land, etc. was, at the time of the transfer, located within a landslide prevention area under Article 3, paragraph (1) of that paragraph and that has purchased, from a person who has received the application of the provisions ofthe Landslide Prevention Act (Act No. 30 of 1958), a steep slope failure hazard area under Article 3, paragraph (3), land, etc. pertaining to the transfer to which the provisions of that paragraph were applied must, where all or part 1) of the Act on Prevention of Disasters Caused by Steep Slope Failure (Act No. 57 of 1969), a special sediment disaster hazard area under Article 9, paragraph (1) of the transfer has come to fall under a transfer Act on Sediment Disaster Countermeasures for Sediment Disaster Prone Areas (Act No. 57 of land, etc. listed in items (xiii) through (xvi) of 2000), or a flood damage prevention area under Article 56, paragraph (2) within1) of the scheduled period, deliver without delay to the person who has received the application Act on Countermeasures against Flood Damage of Specified Rivers Running Across Cities (Act No. 77 of 2003), the provisionstransfer of paragraph (3), with regard that land, etc. is deemed not to the transfer that has come to so fall, a document specified by Order of the Ministry of Finance certifying that it has come to so fallfall under a transfer for a superior residential area, etc. or a transfer for a determined site for constructing a superior residential area, etc. prescribed in paragraph (1) or paragraph (3).

Where a person who has receivedAn individual or a corporation that carries out the application of development referred to in paragraph (2), item (xiii) or item (xiv) or the provisions of paragraph (3) construction referred to in item (xv) or item (xvi) of that paragraph and that has purchased, from a person who has received the deliveryapplication of the document prescribed in the preceding paragraphprovisions of paragraph (3), land, etc. pertaining to the transfer to which the provisions of paragraph (3)that paragraph were applied, must, where all or part of the person must submit transfer has come to fall under a transfer of land, etc. listed in items (xiii) through (xvi) of paragraph (2) within the document scheduled period, deliver without delay to the district director having jurisdiction over person who has received the application of the place for tax payment, pursuant provisions of paragraph (3), with regard to the provisions of transfer that has come to so fall, a document specified by Order of the Ministry of Finance certifying that it has come to so fall.

Where it has become difficult for all or part of a transfera person who has received the application of land, etc. to which the provisions of paragraph (3) were applied to fall under a transfer of land, etc. listed in items (xiii) through (xvi)has received the delivery of paragraph (2) within the scheduled perioddocument prescribed in paragraph (3), due to unavoidable circumstances arising from an emergency disaster designated as a specified emergency disaster pursuant to the provisions of Article 2,preceding paragraph (1) of the Act on Special Measures concerning Preservation of Rights and Interests of Victims of Specified Disaster, in a case specified by Cabinet Order, if it has been certified, pursuantpertaining to the provisions of Order of the Ministry of Finance, that all or part of the transfer is found certain to come to fall under a transferwhich the provisions of land, etc. listed in items (xiii) through (xvi) of that paragraph during the period fromparagraph (3) were applied, the first day ofperson must submit the scheduled period untildocument to the date specified by Cabinet Order that falls within two years afterdistrict director having jurisdiction over the last day of the scheduled period, then with regardplace for tax payment, pursuant to the application of the provisions of paragraph (3), paragraph (5), and the following paragraph through paragraph (10), the scheduled period prescribed in paragraph (3) isOrder of the period from that first day until that date specified by Cabinet OrderMinistry of Finance.

Where it has become difficult for all or part of thea transfer of land, etc. to which the provisions of paragraph (3) were applied has come not to fall under a transfer of land, etc. listed in items (xiii) through (xvi) of paragraph (2) within the scheduled period prescribed in paragraph (3), the person who has received the application of due to unavoidable circumstances arising from an emergency disaster designated as a specified emergency disaster pursuant to the provisions of Article 2, paragraph (3) must, within four months from the day on which the scheduled period 1) of the Act on Special Measures concerning Preservation of Rights and Interests of Victims of Specified Disaster, in a case specified by Cabinet Order, if it has elapsed, file an amended returnbeen certified, pursuant to the provisions of income tax forOrder of the year Ministry of Finance, that includes the dateall or part of the transfer is found certain to which the provisions come to fall under a transfer of paragraph (3) were applied, and must pay, within that time limit,land, etc. listed in items (xiii) through (xvi) of that paragraph during the period from the amount first day of tax to be paid upon filing the scheduled period until the date specified by Cabinet Order that return. In this case, notwithstanding falls within two years after the last day of the scheduled period, then with regard to the application of the provisions of that paragraph (3), paragraph, the transfer that has come not to so fall is deemed not to have been a transfer for a determined site for constructing a superior residential area, etc (6), and the following paragraph through paragraph (11), the scheduled period prescribed in paragraph (3) is the period from that first day until that date specified by Cabinet Order.

In the case referred Where all or part of the transfer to inwhich the preceding provisions of paragraph, if the amended return is (3) were applied has come not filed, the district director having jurisdiction over to fall under a transfer of land, etc. listed in items (xiii) through (xvi) of paragraph (2) within the place for tax payment is to make a reassessment pursuant toscheduled period prescribed in paragraph (3), the person who has received the application of the provisions of Article 24 or Article 26 of paragraph (3) must, within four months from the Actday on General Rules which the scheduled period has elapsed, file an amended return of income tax for National Taxes with regard the year that includes the date of the transfer to which the amountprovisions of income, paragraph (3) were applied, and must pay, within that time limit, the amount of income tax, and other matters to be paid upon filing that return. In this case, notwithstanding the provisions of that should paragraph, the transfer that has come not to so fall is deemed not to have been stated in that returna transfer for a determined site for constructing a superior residential area, etc.

With regard In the case referred to in the application of preceding paragraph, if the amended return is not filed, the district director having jurisdiction over the place for tax payment is to make a reassessment pursuant to the provisions of Article 24 or Article 26 of the Act on General Rules for National Taxes with regard to an amended return underthe amount of income, the provisionsamount of paragraph (8)income tax, and to the reassessment set forth in the preceding paragraph, the following provisions apply:other matters that should have been stated in that return.

an amended return that is filed within the time limit for filing prescribed in paragraph (8) is deemed to be a return filed by the due date prescribed in Article 17, paragraph (2) of the Act on General Rules for National Taxes, except where the provisions of Article 20 of that Act are applied;

with regard to an amended return that is filed after the time limit for filing prescribed in paragraph (8) and to the reassessment, in the provisions of Chapter II through Chapter VII of the Act on General Rules for National Taxes, the phrases "statutory due date for filing a return" and "statutory due date for payment" are deemed to be replaced with "the time limit for filing an amended return prescribed in Article 31-2, paragraph (8) of the Act on Special Measures Concerning Taxation"; in Article 61, paragraph (1), item (i) of that Act, the phrase "return filed by the due date" is deemed to be replaced with "final return prescribed in Article 2, paragraph (1), item (x) of the Act on Special Measures Concerning Taxation"; in paragraph (2) of that Article, the phrase "return filed by the due date or return filed after the due date" is deemed to be replaced with "amended return under the provisions of Article 31-2, paragraph (8) of the Act on Special Measures Concerning Taxation"; and in Article 65, paragraph (1), paragraph (3), item (ii), and paragraph (5), item (ii) of that Act, the phrase "return filed by the due date" is deemed to be replaced with "final return prescribed in Article 2, paragraph (1), item (x) of the Act on Special Measures Concerning Taxation";

the provisions of Article 61, paragraph (1), item (ii) and Article 66 of the Act on General Rules for National Taxes do not apply to the amended return and the reassessment prescribed in the preceding item.

With regard to the application of the provisions of the Act on General Rules for National Taxes to an amended return under the provisions of paragraph (9) and to the reassessment set forth in the preceding paragraph, the following provisions apply:

an amended return that is filed within the time limit for filing prescribed in paragraph (9) is deemed to be a return filed by the due date prescribed in Article 17, paragraph (2) of the Act on General Rules for National Taxes, except where the provisions of Article 20 of that Act are applied;

with regard to an amended return that is filed after the time limit for filing prescribed in paragraph (9) and to the reassessment, in the provisions of Chapter II through Chapter VII of the Act on General Rules for National Taxes, the phrases "statutory due date for filing a return" and "statutory due date for payment" are deemed to be replaced with "the time limit for filing an amended return prescribed in Article 31-2, paragraph (9) of the Act on Special Measures Concerning Taxation"; in Article 61, paragraph (1), item (i) of that Act, the phrase "return filed by the due date" is deemed to be replaced with "final return prescribed in Article 2, paragraph (1), item (x) of the Act on Special Measures Concerning Taxation"; in paragraph (2) of that Article, the phrase "return filed by the due date or return filed after the due date" is deemed to be replaced with "amended return under the provisions of Article 31-2, paragraph (9) of the Act on Special Measures Concerning Taxation"; and in Article 65, paragraph (1), paragraph (3), item (ii), and paragraph (5), item (ii) of that Act, the phrase "return filed by the due date" is deemed to be replaced with "final return prescribed in Article 2, paragraph (1), item (x) of the Act on Special Measures Concerning Taxation";

the provisions of Article 61, paragraph (1), item (ii) and Article 66 of the Act on General Rules for National Taxes do not apply to the amended return and the reassessment prescribed in the preceding item.

A resident or nonresident who has a permanent establishment prescribed in paragraph (1) who has acquired deductible specified shares by payment on or after January 1, 2026 may, if there is an undeducted amount for specified shares arising in that year (meaning, where the total amount of income from transfer, etc. of shares, etc. before application for that year is less than the total of the deductible acquisition cost of specified shares, the amount calculated pursuant to the provisions of Cabinet Order as the portion of the shortfall pertaining to specified shares specified in item (i) or item (ii) of that paragraph; the same applies hereinafter in this Article), claim from the competent district director for the place for tax payment, at the same time as filing the final return for that year (including a return under the provisions of Article 123, paragraph (1) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) as applied mutatis mutandis pursuant to paragraph (9) of the preceding Article (including as applied mutatis mutandis pursuant to Article 37-13-3, paragraph (10)), Article 38-3, paragraph (5), or Article 41-15, paragraph (5); the same applies in paragraphs (5) and (9)), a refund of the income tax equivalent to the amount obtained by deducting the amount listed in item (ii) of this paragraph from the amount listed in item (i):

the provisions of paragraph (3) through the preceding paragraph apply mutatis mutandis to the case where a claim for a refund under the preceding item is made. In this case, in paragraph (3), the phrase "from the competent district director for the place for tax payment, at the same time as filing the final return for that year (including a return under the provisions of Article 123, paragraph (1) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) as applied mutatis mutandis pursuant to paragraph (9) of the preceding Article (including as applied mutatis mutandis pursuant to Article 37-13-3, paragraph (10)), Article 38-3, paragraph (5), or Article 41-15, paragraph (5); the same applies in paragraphs (5) and (9))," is deemed to be replaced with "from the competent district director for the place for tax payment,"; in item (i) of that paragraph, the phrase "this paragraph" is deemed to be replaced with "this paragraph as applied mutatis mutandis pursuant to paragraph (9), item (ii)"; in paragraph (4), the phrase "the provisions of the preceding paragraph" is deemed to be replaced with "the provisions of the preceding paragraph as applied mutatis mutandis pursuant to paragraph (9), item (ii)"; in paragraph (5), the phrase "has filed the final return for that year by its filing deadline (including, where the district director finds that there are unavoidable circumstances, where the person filed that return after its filing deadline" is deemed to be replaced with "has submitted the claim for a refund referred to in paragraph (10) by March 15 of the year following that year (or, where the absence from Japan (meaning absence from Japan prescribed in paragraph (9); the same applies hereinafter in this paragraph and paragraph (8)) of the person occurs before that day, the time of that absence from Japan; the same applies hereinafter in this paragraph) (including, where the district director finds that there are unavoidable circumstances, where the person submitted that claim for a refund after March 15 of the year following that year"; in paragraph (6), the phrase "A person who falls under the provisions of Article 125, paragraphs (1) through (3) or paragraph (5) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) and files the return prescribed in those provisions may, where there is an undeducted amount for specified shares arising in that year of the resident or nonresident who has a permanent establishment referred to in paragraph (3) who died during that year" is deemed to be replaced with "Where the resident or nonresident who has a permanent establishment referred to in paragraph (3) has died during the year, if there is an undeducted amount for specified shares of that person arising in that year, their heir, etc. (meaning an heir, etc. prescribed in paragraph (9)) may", and the phrase "at the same time as filing that return, claim from the competent district director for the place for tax payment for the income tax pertaining to that return" is deemed to be replaced with "claim from the competent district director for the place for tax payment of that resident or nonresident who has a permanent establishment"; in item (i) of that paragraph, the phrase "this paragraph" is deemed to be replaced with "this paragraph as applied mutatis mutandis pursuant to paragraph (9), item (ii)"; and in the preceding paragraph, the phrase "the person who files the return prescribed in paragraph (6) has filed that return by its filing deadline (including, where the district director finds that there are unavoidable circumstances, where that person filed that return after its filing deadline" is deemed to be replaced with "the heir, etc. prescribed in paragraph (6) has submitted the claim for a refund referred to in paragraph (10) by the day before the day on which four months have elapsed from the day following the day on which the heir, etc. came to know of the commencement of the succession (or, where the absence from Japan of that heir, etc. occurs before that day, the time of that absence from Japan; the same applies hereinafter in this paragraph) (including, where the district director finds that there are unavoidable circumstances, where the heir, etc. submitted that claim for a refund after the day before the day on which those four months have elapsed".

Subsection 9-2 Special Provisions, etc. on Taxation on Income from the Transfer of Specified Crypto Assets

Where a resident or a nonresident who has a permanent establishment has made a transfer of a crypto asset prescribed in Article 2, paragraph (49) of the Financial Instruments and Exchange Act (limited to one whose name is registered in the register of financial instruments business operators prescribed in Article 29-3, paragraph (1) of that Act as a matter listed in Article 29-2, paragraph (1), item (xi), (a) of that Act (excluding one specified by Order of the Ministry of Finance in consideration of the state of its trading and other circumstances) or any other one specified by Order of the Ministry of Finance; hereinafter referred to in this paragraph, paragraphs (4) and (5) and paragraph (2) of the following Article as a "specified crypto asset") (limited to a transfer made through a sell order entrusted to a financial instruments business operator prescribed in Article 2, paragraph (9) of that Act (limited to one that conducts the crypto asset trading business prescribed in Article 28, paragraph (5) of that Act; hereinafter referred to in this paragraph and paragraph (4) as a "crypto asset trading business operator") or a transfer to a crypto asset trading business operator; the same applies hereinafter in this paragraph and in paragraph (2) of the following Article), with respect to the business income, capital gains and miscellaneous income from the transfer of the specified crypto asset, notwithstanding the provisions of Articles 22 and 89 and Article 165 of the Income Tax Act, income tax is imposed, separately from other income, on the amount calculated pursuant to the provisions of Cabinet Order as the amount of business income, the amount of capital gains and the amount of miscellaneous income from the transfer of the specified crypto asset during that year (hereinafter referred to in this paragraph as the "amount of capital gains, etc. on specified crypto assets"), in an amount equivalent to 15 percent of the amount of taxable capital gains, etc. on specified crypto assets (meaning the amount of capital gains, etc. on specified crypto assets (where the provisions of Articles 72 through 87 of that Act as replaced pursuant to the provisions of item (iii) of the following paragraph apply, the amount after that application)). In this case, if there is an amount of losses arising in the calculation of the amount of capital gains, etc. on specified crypto assets, the amount of losses is deemed not to have arisen for the purpose of applying the provisions of that Act and other laws and regulations concerning income tax.

Where the provisions of the preceding paragraph apply, the following applies:

for the purpose of applying the provisions of Article 2, paragraph (1), items (xxx) through (xxxiv)-5 of the Income Tax Act, the phrase "amount of timber income" in item (xxx) of that paragraph is deemed to be replaced with "amount of timber income and the amount of capital gains, etc. on specified crypto assets prescribed in Article 38-2, paragraph (1) (Special Provisions on Taxation on Capital Gains, etc. on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation (hereinafter referred to as the 'amount of capital gains, etc. on specified crypto assets')";

for the purpose of applying the provisions of Article 69 of the Income Tax Act, the phrase "amount of capital gains" in paragraph (1) of that Article is deemed to be replaced with "amount of capital gains (for the amount of business income and the amount of capital gains, the amount calculated as if there were no business income or capital gains from the transfer, prescribed in Article 38-2, paragraph (1) (Special Provisions on Taxation on Capital Gains, etc. on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation, of specified crypto assets prescribed in that paragraph)", and the phrase "amount of each type of income" is deemed to be replaced with "amount of each type of income (excluding the amount of capital gains, etc. on specified crypto assets)";

for the purpose of applying the provisions of Article 71 and Articles 72 through 87 of the Income Tax Act, the phrase "amount of gross income" in those provisions is deemed to be replaced with "amount of gross income, amount of capital gains, etc. on specified crypto assets";

for the purpose of applying the provisions of Articles 92, 95 and 165-6 of the Income Tax Act, the phrase "the preceding Section (Tax Rates)" in Article 92, paragraph (1) of that Act is deemed to be replaced with "the preceding Section (Tax Rates) and Article 38-2, paragraph (1) (Special Provisions on Taxation on Capital Gains, etc. on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation", the phrase "taxable gross income" is deemed to be replaced with "the sum of the taxable gross income and the amount of taxable capital gains, etc. on specified crypto assets prescribed in Article 38-2, paragraph (1) of the Act on Special Measures Concerning Taxation", the phrase "amount of income tax on taxable gross income" in paragraph (2) of that Article is deemed to be replaced with "amount of income tax on taxable gross income, the amount of income tax on the amount of taxable capital gains, etc. on specified crypto assets prescribed in that paragraph", and the phrase "amount of income tax for that year" in Article 95 and Article 165-6 of that Act is deemed to be replaced with "amount of income tax for that year and the amount of income tax under the provisions of Article 38-2, paragraph (1) (Special Provisions on Taxation on Capital Gains, etc. on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation";

beyond what is specified in the preceding items, special provisions concerning applications or returns under the provisions of Part II, Chapter V of the Income Tax Act and other necessary matters concerning the application of the provisions of laws and regulations on income tax in the case where the provisions of the preceding paragraph apply are specified by Cabinet Order.

Beyond what is provided for in the preceding paragraph, necessary matters concerning the application of the provisions of paragraph (1) are specified by Cabinet Order.

The head of the business office (meaning the principal business office or office in Japan; the same applies hereinafter in this paragraph) of a crypto asset trading business operator that has conducted an act listed in Article 2, paragraph (8), item (xviii) or (xix) of the Financial Instruments and Exchange Act with respect to a specified crypto asset with a resident or a nonresident who has a permanent establishment must, by January 31 of the year following the year that includes the day on which the act was conducted, prepare a report stating the name and individual number of the resident or nonresident who has a permanent establishment, the name of the specified crypto asset, and other matters specified by Order of the Ministry of Finance, and submit it to the district director with jurisdiction over the location of the business office.

The relevant official of the National Tax Agency, the Regional Taxation Bureau, or the tax office may, when necessary for an investigation concerning the submission of the report referred to in the preceding paragraph, ask questions of the person who is obliged to submit that report, inspect that person's books and documents and other articles concerning the act prescribed in that paragraph with respect to the specified crypto asset referred to in that paragraph, or request the presentation or submission of those articles (including copies thereof).

The relevant official of the National Tax Agency, the Regional Taxation Bureau, or the tax office may, when necessary for an investigation concerning the submission of the report referred to in paragraph (4), retain articles submitted in that investigation.

The relevant official of the National Tax Agency, the Regional Taxation Bureau, or the tax office, when asking questions, conducting an inspection, or requesting presentation or submission pursuant to the provisions of paragraph (5), must carry an identification card and present it to the person concerned when requested.

The authority of the officials under the provisions of paragraph (5) and paragraph (6) must not be construed as being granted for the purpose of criminal investigation.

Beyond what is provided for in the preceding paragraph, necessary matters concerning the application of the provisions of paragraph (6) are specified by Cabinet Order.

Where a resident or a nonresident who has a permanent establishment who files a final return (including a return under the provisions of Article 123, paragraph (1) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) as applied mutatis mutandis pursuant to paragraph (5); hereinafter the same applies in this paragraph and paragraph (3)) has an amount of capital losses on specified crypto assets that arose in any year within the three years before that year (excluding any amount deducted in or before the previous year by applying the provisions of this paragraph), notwithstanding the provisions of the second sentence of paragraph (1) of the preceding Article, an amount equivalent to that amount of capital losses on specified crypto assets is, pursuant to the provisions of Cabinet Order, deducted in calculating the amount of capital gains, etc. on specified crypto assets for the year covered by the final return, up to the amount of capital gains, etc. on specified crypto assets prescribed in that paragraph for that year.

The amount of capital losses on specified crypto assets prescribed in the preceding paragraph means, out of the amount calculated pursuant to the provisions of Cabinet Order as the amount of losses arising from the resident or nonresident who has a permanent establishment prescribed in that paragraph having made a transfer of specified crypto assets, the amount calculated pursuant to the provisions of Cabinet Order as the portion that cannot be fully deducted even after deduction in calculating the amount of capital gains, etc. on specified crypto assets prescribed in paragraph (1) of the preceding Article for the year that includes the day on which the person made that transfer.

The provisions of paragraph (1) apply only where the resident or nonresident who has a permanent establishment prescribed in that paragraph has filed, for income tax for the year in which the amount of capital losses on specified crypto assets prescribed in the preceding paragraph arose, a final return to which a written statement concerning the calculation of that amount of capital losses on specified crypto assets and other documents specified by Order of the Ministry of Finance are attached, and has continuously filed final returns thereafter, and where the final return referred to in paragraph (1) has attached to it a written statement concerning the calculation of the amount to be deducted under the provisions of that paragraph and other documents specified by Order of the Ministry of Finance.

With regard to the application of the provisions of the preceding Article (excluding paragraph (2)) in the case where the provisions of paragraph (1) apply, the phrase "calculated amount (" in paragraph (1) of that Article is deemed to be replaced with "calculated amount (where the provisions of paragraph (1) of the following Article apply, the amount after that application;".

The provisions of Article 123, paragraph (1) (excluding item (ii)) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) apply mutatis mutandis to the case where a resident or a nonresident who has a permanent establishment seeks the application of the provisions of paragraph (1) in or after the year following the relevant year, and the case falls under neither the case where the person must file a return under the provisions of Article 120, paragraph (1) of that Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) for income tax for the relevant year nor the case where the person may file a return under the provisions of Article 122, paragraph (1) or Article 123, paragraph (1) of that Act (including as applied mutatis mutandis pursuant to Article 166 of that Act). In this case, in paragraph (1) of that Article, the phrase "seeks the application of the provisions of Article 70, paragraph (1) or paragraph (2) (Deduction for Carryover of Net Loss) or Article 71, paragraph (1) (Deduction for Carryover of Casualty Loss), or seeks a refund under the provisions of Article 142, paragraph (2) (Procedures for Issuing Refunds Based on Carryback of Net Loss), during the third period" is deemed to be replaced with "seeks the application of the provisions of Article 38-3, paragraph (1) (Deduction for Carryover of Capital Losses on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation", and the phrase "listed in the items of the following paragraph" is deemed to be replaced with "the amount of capital losses on specified crypto assets prescribed in paragraph (2) of that Article that arose in that year (hereinafter referred to in this paragraph as the 'amount of capital losses on specified crypto assets'), the amount of capital losses on specified crypto assets that arose in each year within the three years before that year, and other matters specified by Cabinet Order"; in item (i) of that paragraph, the phrase "amount of net loss" is deemed to be replaced with "amount of capital losses on specified crypto assets"; and in item (iii) of that paragraph, the phrase "amount of net loss and casualty loss (Article 70, paragraph (1) or paragraph (2) or Article 71, paragraph (1)" is deemed to be replaced with "amount of capital losses on specified crypto assets (Article 38-3, paragraph (1) of the Act on Special Measures Concerning Taxation", the phrase "and excluding those that formed the basis for calculating the amount to be refunded pursuant to the provisions of Article 142, paragraph (2); the same applies in that item" is deemed to be replaced with "excluding", the phrase "those amounts" is deemed to be replaced with "that amount of capital losses on specified crypto assets", and the phrase "the sum of the amount of gross income, the amount of retirement income and the amount of timber income" is deemed to be replaced with "the amount of capital gains, etc. on specified crypto assets prescribed in Article 38-2, paragraph (1) (Special Provisions on Taxation on Capital Gains, etc. on Specified Crypto Assets) of that Act".

With regard to the application of the provisions of the Act on General Rules for National Taxes in the case where the provisions of paragraph (1) apply, in Article 2, item (vi), (c)(1) of that Act, the phrase "or casualty loss" is deemed to be replaced with "or casualty loss, or the amount of capital losses on specified crypto assets prescribed in Article 38-3, paragraph (2) (Deduction for Carryover of Capital Losses on Specified Crypto Assets) of the Act on Special Measures Concerning Taxation", and the phrase "that Act" is deemed to be replaced with "those Acts".

Special provisions on the matters to be stated in the final return to be filed in the case where the application of the provisions of paragraph (1) is sought in or after the year following the relevant year or in that year, and other necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.

financial instruments futures transactions, etc. (meaning, among transactions listed in Article 2, paragraph (21), items (i) through (iii) of the Financial Instruments and Exchange Act (for transactions listed in item (iii) of that paragraph, excluding those pertaining to rights to effect the transactions listed in items (iv) through (vi) of that paragraph) that fall under market transactions of derivatives prescribed in that paragraph (excluding those pertaining to crypto assets, etc. listed in Article 2, paragraph (24), item (iii)-2 of that Act other than specified crypto assets prescribed in Article 38-2, paragraph (1), or financial indicators prescribed in Article 29-2, paragraph (1), item (ix) of that Act pertaining to those crypto assets, etc.), those specified by Cabinet Order, or transactions listed in Article 2, paragraph (22), items (i) through (iv) of that Act (for transactions listed in item (iii) of that paragraph, excluding those pertaining to rights to effect the transactions listed in items (v) through (vii) of that paragraph) that fall under over-the-counter transactions of derivatives prescribed in that paragraph (excluding those pertaining to crypto assets, etc. listed in Article 2, paragraph (24), item (iii)-2 of that Act other than specified crypto assets prescribed in Article 38-2, paragraph (1), or financial indicators prescribed in Article 29-2, paragraph (1), item (ix) of that Act pertaining to those crypto assets, etc.) (limited to those conducted with a financial instruments business operator or registered financial institution prescribed in Article 37-12-2, paragraph (2), item (i) as the counterparty); hereinafter the same applies in this item): settlement of the financial instruments futures transactions, etc. (excluding settlement that results in delivery of the financial instruments prescribed in Article 2, paragraph (24) of that Act pertaining to the financial instruments futures transactions, etc.);

the sum of the amount of gross income, the amount of retirement income and the amount of timber income prescribed in Article 22 of the Income Tax Act (including where the calculation is made in accordance with that Article pursuant to the provisions of Article 165, paragraph (1) of that Act), calculated as if the provisions of Article 8-5, paragraph (1) did not apply (excluding the amounts listed in the following item through item (ixx));

the amount of miscellaneous incomecapital gains, etc. from futures transactions on specified crypto assets prescribed in Article 41-1438-2, paragraph (1).;

the amount of miscellaneous income, etc. from futures transactions prescribed in Article 41-14, paragraph (1).

With regard to the reports and statements prescribed in Article 8-4, paragraph (9), Article 9-4-2, paragraph (2), Article 29-2, paragraph (6) or (7), Article 37-11-3, paragraph (7), Article 37-14, paragraph (41), Article 37-14-2, paragraph (27), Article 38-2, paragraph (4) or Article 41-2-3, paragraph (2) that are to be submitted under those provisions (hereinafter referred to as "statements and similar reports" in this Article), where the number calculated as provided by Order of the Ministry of Finance as the number of sheets of those statements and similar reports that should have been submitted during the period from January 1 to December 31 of the year before the year preceding the year that includes the due date for submitting those statements and similar reports is 30 or more, the person required to submit those statements and similar reports must, notwithstanding those provisions, provide the matters prescribed in those provisions that are to be stated in those statements and similar reports (hereinafter referred to as the "required particulars" in this Article) to the district director prescribed in those provisions by either of the following methods:

If a person required to submit statements and similar reports has obtained, as provided by Cabinet Order, the approval of the competent district director (meaning the district director prescribed in Article 8-4, paragraph (9), Article 9-4-2, paragraph (2), Article 29-2, paragraph (6) or (7), Article 37-11-3, paragraph (7), Article 37-14, paragraph (41), Article 37-14-2, paragraph (27), Article 38-2, paragraph (4) or Article 41-2-3, paragraph (2)), the person may, notwithstanding those provisions and the provisions of paragraph (1), provide the required particulars of those statements and similar reports to the district director specified by Order of the Ministry of Finance by either of the methods listed in the items of that paragraph.

With regard to the provision of the required particulars made under the provisions of paragraph (1) or the preceding paragraph and the submission of an optical disc or similar medium made under the provisions of paragraph (2), the statements and similar reports are deemed to have been submitted under the provisions of Article 8-4, paragraph (9), Article 9-4-2, paragraph (2), Article 29-2, paragraph (6) or (7), Article 37-11-3, paragraph (7), Article 37-14, paragraph (41), Article 37-14-2, paragraph (27) , Article 38-2, paragraph (4) or Article 41-2-3, paragraph (2), and those provisions, Article 8-4, paragraphs (10) through (14), Article 9-4-2, paragraphs (3) through (7), Article 29-2, paragraphs (9) through (13), Article 37-11-3, paragraphs (12) through (16), Article 37-14, paragraphs (46) through (50), Article 37-14-2, paragraphs (32) through (36), Article 38-2, paragraphs (5) through (9), Article 41-2-3, paragraphs (3) through (7) and the following Article apply.

If a person has evaded income tax with respect to the amount of income tax prescribed in Article 120, paragraph (1), item (iii) of the Income Tax Act (including as applied mutatis mutandis pursuant to Article 166 of that Act) (or, if there is an amount to be deducted under the provisions of Article 95 or 165-6 of that Act, the amount of income tax calculated under the provisions of that item without applying those provisions) by failing to file, by the due date for filing those returns, an amended return or a return filed after the due date under the provisions of Article 28-3, paragraph (7), Article 30-2, paragraph (5), Article 31-2, paragraph (89), Article 33-5, paragraph (1), Article 35, paragraph (9), Article 36-3, paragraphs (1) through (3) (including as applied by deeming pursuant to the provisions of Article 36-5), Article 37-2, paragraph (1) or (2) (including as applied by deeming pursuant to the provisions of Article 37-4 and as applied mutatis mutandis pursuant to Article 37-5, paragraph (3) (including as applied by deeming pursuant to the provisions of paragraph (5) of that Article)), Article 41-3, paragraph (1), Article 41-5, paragraph (13) or (14) or Article 41-19-4, paragraph (14), the person who committed the violation is punished by imprisonment for five years or less or a fine of 5,000,000 yen or less, or both.

If a person has failed, without justifiable grounds, to file an amended return or a return filed after the due date under the provisions of Article 28-3, paragraph (7), Article 30-2, paragraph (5), Article 31-2, paragraph (89), Article 33-5, paragraph (1), Article 35, paragraph (9), Article 36-3, paragraphs (1) through (3) (including as applied by deeming pursuant to the provisions of Article 36-5), Article 37-2, paragraph (1) or (2) (including as applied by deeming pursuant to the provisions of Article 37-4 and as applied mutatis mutandis pursuant to Article 37-5, paragraph (3) (including as applied by deeming pursuant to the provisions of paragraph (5) of that Article)), Article 41-3, paragraph (1), Article 41-5, paragraph (13) or (14) or Article 41-19-4, paragraph (14) by the due date for filing those returns, the person who committed the violation is punished by imprisonment for one year or less or a fine of 500,000 yen or less; provided, however, that the punishment may be remitted depending on the circumstances.

when the person has failed to submit the report prescribed in Article 8-4, paragraph (9), the payment report on redemption money, etc. of listed securities investment trusts, etc. prescribed in Article 9-4-2, paragraph (2), the report on the granting of specified share options prescribed in Article 29-2, paragraph (6) or the report on changes of specified shares, etc. prescribed in paragraph (7) of the Article, the report prescribed in Article 37-11-3, paragraph (7), the report prescribed in Article 37-14, paragraph (41), the report prescribed in Article 37-14-2, paragraph (27), the report prescribed in Article 38-2, paragraph (4) or the statement prescribed in Article 41-2-3, paragraph (2), to the district director no later than the due date for submitting such report or statement, or has made false entries or records in such report or statement and has submitted the report or statement to the district director;

when the person has failed to answer or has given a false answer to the questions asked by the relevant officials pursuant to the provisions of Article 8-4, paragraph (10), Article 9-4-2, paragraph (3), Article 29-2, paragraph (9), Article 37-11-3, paragraph (12), Article 37-14, paragraph (46), Article 37-14-2, paragraph (32), Article 38-2, paragraph (5) or Article 41-2-3, paragraph (3), or has refused, obstructed, or avoided the inspection under those provisions;

when the person, without justifiable grounds, has failed to comply with a request for the presentation or submission of articles under the provisions of Article 8-4, paragraph (10), Article 9-4-2, paragraph (3), Article 29-2, paragraph (9), Article 37-11-3, paragraph (12), Article 37-14, paragraph (46), Article 37-14-2, paragraph (32), Article 38-2, paragraph (5) or Article 41-2-3, paragraph (3), or has presented or submitted books and documents or other articles (including copies thereof) containing false entries or records.

the provisions of Article 62, paragraph (1), Article 62-3, paragraphs (1) and (910), and Article 63, paragraph (1);

A corporation (excluding a public corporation; hereinafter the same applies in this paragraph) is liable to pay corporation tax on its expenditure for undisclosed purposes, and where a corporation has made an expenditure for undisclosed purposes on or after April 1, 1994, the amount of corporation tax on income for each business year imposed on that corporation is, notwithstanding the provisions of Article 66, paragraphs (1) through (3) and paragraph (6), Article 69, paragraph (19) (including as applied mutatis mutandis pursuant to paragraph (23) or paragraph (24) of that Article), and Article 143, paragraphs (1) and (2) of the Corporation Tax Act, the provisions of Article 42-4, paragraph (8), item (vi), (b) and item (vii) (including as applied mutatis mutandis pursuant to Article 42-4-2, paragraph (2) or Article 42-5, paragraph (3), item (ii)), Article 42-14, paragraphs (1) and (4), Article 62-3, paragraphs (1) and (910), Article 63, paragraph (1), Article 67-2, paragraph (1), and Article 68, paragraph (1), and other provisions of laws and regulations concerning corporation tax, the amount obtained by adding the amount calculated by multiplying the amount of that expenditure for undisclosed purposes by the rate of 40 percent to the amount of corporation tax calculated pursuant to those provisions.

Where a corporation has made a transfer, etc. of land, the amount of corporation tax to be imposed on the corporation on its income for each business year is to be, notwithstanding the provisions of Article 66, paragraphs (1) to (3) and paragraph (6), Article 69, paragraph (19) (including as applied mutatis mutandis pursuant to paragraph (23) or paragraph (24) of that Article), and Article 143, paragraph (1) and paragraph (2) of the Corporation Tax Act, the provisions of Article 42-4, paragraph (8), item (vi), (b) and item (vii) (including as applied mutatis mutandis pursuant to Article 42-4-2, paragraph (2) or Article 42-5, paragraph (3), item (ii)), Article 42-14, paragraph (1) and paragraph (4), Article 62, paragraph (1) and paragraph (910), paragraph (1) of the following Article, Article 67-2, paragraph (1), and Article 68, paragraph (1), and the provisions of other corporation tax-related laws and regulations, the sum of the amount of corporation tax calculated pursuant to these provisions plus the amount obtained by multiplying the total of the amount of capital gain from the transfer, etc. of land (excluding transfer, etc. to which the provisions of paragraph (1) of the following Article applies) by the rate of five percent.

The provisions of paragraph (1) do not apply to the case where a corporation has made transfer of its land, etc. (excluding land, etc. falling under the category of inventory assets; hereinafter the same applies through to paragraph (910) and in paragraph (1112)) during the period between January 1, 1992 and December 31, 2028 and when it has been certified, as specified by Order of the Ministry of Finance, that the transfer of the land, etc. falls under the category of the following transfers of land, etc.:

transfer of land, etc. to an individual or a corporation that is to carry out the development of a unit of residential land for use in residential construction (limited to that which meets the following requirements) after obtaining permission under Article 29, paragraph (1) of the City Planning Act (limited to permission pertaining to development activities prescribed in Article 4, paragraph (12) of that Act that are carried out within an area specified by Cabinet Order within a city planning area prescribed in paragraph (2) of that Article; hereinafter referred to in this item as a "development permit") (in the case where there has been a succession to the status based on a development permit prescribed in Article 44 or Article 45 of that Act, such individual is to be the individual who was the transferor in the succession or the individual who has succeeded to the status; the same applies in paragraph (78)) (in the case where there has been a succession to the status based on a development permit prescribed in Article 44 or Article 45 of that Act, such corporation is to be the corporation that was the transferor in the succession or the corporation that has succeeded to the status; the same applies in paragraph (78)), with the transferred land, etc. being used for the unit of residential land (excluding that which falls under the category of a transfer listed in items (vii) through (ix)):

in cases where permission under Article 29, paragraph (1) of the City Planning Act is not required for development of a unit of residential land, the transfer of land, etc. to an individual or a corporation that is to carry out the development of the unit of residential land for use in residential construction (limited to that which meets the following requirements) (in the case where an heir or universal legatee has succeeded to the project for the development due to the death of the individual who was carrying out the development, and where the heir or universal legatee then carries out the development, such individual is to be the deceased individual who was to carry out the development or the heir or universal legatee; the same applies in paragraph (78)) (in the case where the corporation carrying out the development has extinguished as a result of a merger and a merging corporation that was involved in the merger has succeeded to the project for the development and carries out the development, such corporation is to be the extinguished corporation that was to carry out the development or the merging corporation; and in the case where the corporation carrying out the development has been split off and the successor corporation in the company split that was involved in the company split has succeeded to the project for the development and carries out the development, such corporation is to be the split-off corporation that was to carry out the development or the successor corporation in the company split; the same applies in paragraph (78)), with the transferred land, etc. being used for the unit of residential land (excluding that which falls under the category of a transfer listed in items (vii) through (ix) or a transfer of land, etc. specified by Cabinet Order):

transfer of land, etc. to an individual or a corporation that is to construct a group of houses or mid-to-high-rise fire-proof apartment houses (each limited to that which meets the following requirements) (in the case where an heir or universal legatee has succeeded to the project for the construction due to the death of the individual carrying out the development, and where the heir or universal legatee then carries out the construction, such individual is to be the deceased individual who was to carry out the construction or the heir or universal legatee; the same applies in the following item and paragraph (78)) (in the case where the corporation carrying out the construction has extinguished as a result of a merger and the merging corporation that was involved in the merger has succeeded to the project for the construction and carries out the construction, such corporation is to be the extinguished corporation that was to carry out the construction or the merging corporation; and in the case where the corporation carrying out the construction has been split off and the successor corporation in the company split that was involved in the company split has succeeded to the project for the construction and carries out the construction, such corporation is to be the split-off corporation that was to carry out the construction or the successor corporation in the company split; the same applies in that item and that paragraph), with the transferred land, etc. being used for constructing the group of houses or mid-to-high-rise fire-proof apartment houses (excluding that which falls under the category of a transfer listed in items (vii) through (ix), item (x), or the preceding two items):

The provisions of the preceding paragraph apply mutatis mutandis in the case where a corporation has made transfer of its land, etc. during the period from January 1, 1992 to December 31, 2028 and when the transfer of the land, etc. falls under the category of a transfer for a determined site for constructing a superior residential area, etc. (meaning transfer that has been certified, as specified by Order of the Ministry of Finance, as highly likely to fall under the category of a transfer of land, etc. listed in items (xiii) through (xvi) of the preceding paragraph during the period from the date of the transfer up to December 31 of the year that includes the day on which two years have elapsed after that date (in the case where the period required for developing residential land to be used for constructing houses generally exceeds two years or there are any other unavoidable reason specified by Cabinet Order, during the period from the date of the transfer up to the date specified by Cabinet Order; referred to in paragraph (78) as the "scheduled period")). In this case, the term "when it has been certified, as specified by Order of the Ministry of Finance, that the transfer of the land, etc. falls under the category of the following transfers of land, etc." in that paragraph is deemed to be replaced with "when the transfer of land, etc. falls under the category of a transfer for a determined site for constructing a superior residential area, etc. prescribed in the following paragraph."

In the case referred to in paragraph (4) (including the case where it is applied mutatis mutandis pursuant to the preceding paragraph; hereinafter the same applies in this paragraph and paragraph (10)Article), when a corporation is subject to the provisions of Article 65-4, paragraph (1) with regard to its land, etc. that has come to fall under the case listed in item (iii) of the paragraph, the transfer of the land, etc. is deemed not to fall under the category of a transfer of land, etc. falling under the provisions of paragraph (4).

An individual or a corporation carrying outIn the development set forthcase referred to in paragraph (4), item (xiii) or item (xiv) or the construction set forth if a corporation has made a transfer that falls under a transfer of land, etc. listed in item (xv) or item (xviitems (xiii) through (xv) of thethat paragraph, that has purchasedand the transferred land, etc. pertaining towas, at the time of the transfer to which the provisions of , located within a landslide prevention area under Article 3, paragraph (5) apply, when1) of the transfer in whole or in part has come to fallLandslide Prevention Act, a steep slope failure hazard area under the category Article 3, paragraph (1) of a transfer the Act on Prevention of land, etc. listed in items (xiii) through (xviDisasters Caused by Steep Slope Failure, a special sediment disaster hazard area under Article 9, paragraph (1) of the paragraph during the scheduled period, must deliver the document specified by Order Act on Sediment Disaster Countermeasures for Sediment Disaster Prone Areas, or a flood damage prevention area under Article 56, paragraph (1) of the Ministry Act on Countermeasures against Flood Damage of Finance that certifies that Specified Rivers Running Across Cities, the transfer of thethat land, etc. has come is deemed not to fall under such category, without delay to the corporation that transferred thea transfer of land, etc. to which that falls under the provisions applyof paragraph (4).

Where it has become difficult for allAn individual or part of a transfer of land, etc. to whicha corporation carrying out the provisions of paragraph (5) were applied to fall under a transfer of land, etc. listeddevelopment set forth in paragraph (4), itemsitem (xiii) through (xvi) withinor item (xiv) or the scheduled period prescribedconstruction set forth in paragraph (5), due to unavoidable circumstances arising from an emergency disaster designated as a specified emergency disaster pursuantitem (xv) or item (xvi) of the paragraph, that has purchased land, etc. pertaining to the transfer to which the provisions of Article 2, paragraph (1) of the Act on Special Measures concerning Preservation of Rights and Interests of Victims of Specified Disaster, in a case specified by Cabinet Order, if it has been certified, as specified by Order of5) apply, when the Ministry of Finance, that alltransfer in whole or part of the transfer is found certain toin part has come to fall under the category of a transfer of land, etc. listed in items (xiii) through (xvi) of thatthe paragraph during the period from the first day of the scheduled period until , must deliver the datedocument specified by Cabinet Order that falls within two years after the last day of the scheduled period, then with regard to the application ofMinistry of Finance that certifies that the provisionstransfer of paragraph (5), the preceding paragraph, and the following paragraph, the scheduled period prescribed in those provisions island, etc. has come to fall under such category, without delay to the period fromcorporation that first day until that date specified by Cabinet Ordertransferred the land, etc. to which the provisions apply.

Where the transfer of land, etc. in wholeit has become difficult for all or in part to which the provisions of paragraph (5) apply (in the case where the corporation is a merging corporation, including transfersa transfer of land, etc. into which a merged corporation involved in the merger is subject to the provisions of that paragraph) does not (5) were applied to fall under the category of a transfer of land, etc. listed in paragraph (4), items (xiii) through (xvi) as of the last day ofwithin the scheduled period prescribed in paragraph (5), the amount of corporation taxdue to be imposed on the corporation on income for the business year containing the day isunavoidable circumstances arising from an emergency disaster designated as a specified emergency disaster pursuant to be, notwithstanding the provisions of Article 66, paragraphs2, paragraph (1) through (3) and paragraph (6), Article 69, paragraph (19) (including as applied mutatis mutandis pursuant to paragraph (23) or paragraph (24) of that Article), and Article 143, paragraph (1) and paragraph (2) of the Corporation Tax Act,of the Act on Special Measures concerning Preservation of Rights and Interests of Victims of Specified Disaster, in a case specified by Cabinet Order, if it has been certified, as specified by Order of the provisionsMinistry of Article 42-4, paragraph (8), item (vi), (b) and item (vii) (including as applied mutatis mutandis pursuantFinance, that all or part of the transfer is found certain to come to Article 42-4-2, paragraph (2) or Article 42-5, paragraph (3), item (ii)), Article 42-14, paragraph (1) and fall under a transfer of land, etc. listed in items (xiii) through (xvi) of that paragraph (4), Article 62, paragraph (1), paragraph (1)during the period from the first day of this Article, paragraph (1) ofthe scheduled period until the following Article, Article 67-2, paragraph (1), and Article 68, paragraph (1), anddate specified by Cabinet Order that falls within two years after the provisions last day of other corporation tax-related laws and regulations, the scheduled period, then with regard to the sumapplication of the amountprovisions of corporation tax calculated pursuant to these provisions plusparagraph (5), the amount specified by Cabinet Order aspreceding paragraph, and the following paragraph, the amount obtained by multiplying the total ofscheduled period prescribed in those provisions is the amount of capital gainperiod from the transfer of land, etc. by the rate of five percentthat first day until that date specified by Cabinet Order.

With regard to the application of the provisions of paragraph (1) inWhere the case where a corporation has made a transfer of land, etc. (excluding a transfer of land, etc. falling underin whole or in part to which the provisions of paragraph (3) and paragraph (4)) (including5) apply (in the case where a mergingthe corporation, etc. as prescribed in Article 64-2, paragraph (4) has succeeded to the amount is a merging corporation, including transfers of the special account prescribedland, etc. in that paragraph, fromwhich a merged corporation, splitting corporation, or corporation making a capital contribution in kind involved in the qualified merger, etc. (meaning a qualified merger, etc. prescribed in is subject to the provisions of that paragraph), which made does not fall under the category of a transfer of land, etc., pursuant to that listed in paragraph, or other cases specified by Cabinet Order), when there is any amount that has been included (4), items (xiii) through (xvi) as of the last day of the scheduled period prescribed in deductible expenses, with regard to paragraph (5), the transferamount of land, etc., pursuantcorporation tax to the provisions of Article 50 ofbe imposed on the Corporation Tax Act orcorporation on income for the provisions of Articles 64 through 65-5-2 or Articles 65-7 through 66 (inbusiness year containing the case where thereday is any amount that has been excluded from deductible expenses pursuant toto be, notwithstanding the provisions of Article 65-6, the amount that remains after deducting the excluded amount; hereinafter referred to in this66, paragraphs (1) through (3) and paragraph as the "amount included in deductible expenses"(6), the amount equivalent to the amount included in deductible expenses isArticle 69, paragraph (19) (including as applied mutatis mutandis pursuant to be deducted from the amountparagraph (23) or paragraph (24) of capital gain for the business year; and when there is any amount that has been included in gross profits, with regard to the transferArticle), and Article 143, paragraph (1) and paragraph (2) of land, etc., pursuant tothe Corporation Tax Act, the provisions of Article 64-2, paragraphs (9) through (12) (including the case where these provisions are42-4, paragraph (8), item (vi), (b) and item (vii) (including as applied mutatis mutandis pursuant to Article 6542-4-2, paragraph (3))2) or Article 42-5, paragraph (3), item (ii)), Article 65-742-14, paragraph (4) (including the case where it is applied mutatis mutandis pursuant to1) and paragraph (4), Article 62, paragraph (1), paragraph (1) of this Article, paragraph (1) of the following Article 65-8, Article 67-2, paragraph (14)1), and Article 65-768, paragraph (12) (including1), and the case where it is applied mutatis mutandis pursuant to Article 65-8, paragraph (15)), or Article 65-8, paragraphs (9) through (12), provisions of other corporation tax-related laws and regulations, the sum of the amount of corporation tax calculated pursuant to these provisions plus the amount equivalent to the included specified by Cabinet Order as the amount is to be added to obtained by multiplying the total of the amount of capital gain forfrom the business yeartransfer of land, etc. by the rate of five percent.

The With regard to the application of the provisions of paragraph (5) apply only 1) in the case where the tax returna corporation has made a transfer of land, etc. has attached thereto the document specified by Order of(excluding a transfer of land, etc. falling under the Ministryprovisions of Finance that certifies that paragraph (3) and paragraph (4)) (including the transfer of landcase where a merging corporation, etc. falls under as prescribed in Article 64-2, paragraph (4) has succeeded to the categoryamount of a transfer for a determined site for constructing a superior residential areathe special account prescribed in that paragraph, from a merged corporation, splitting corporation, or corporation making a capital contribution in kind involved in the qualified merger, etc. as (meaning a qualified merger, etc. prescribed in that paragraph and a document stating the amount ), which made the transfer of land, etc., pursuant to that paragraph, or other cases specified by Cabinet Order ), when there is any amount that has been included in deductible expenses, with regard to the transfer of land, etc., pursuant to the provisions of Article 50 of the Corporation Tax Act or the provisions of Articles 64 through 65-5-2 or Articles 65-7 through 66 (in the case where there is any amount that has been excluded from deductible expenses pursuant to the provisions of Article 65-6, the amount that remains after deducting the excluded amount; hereinafter referred to in this paragraph as the "amount included in deductible expenses"), the amount equivalent to the amount included in deductible expenses is to be deducted from the amount of capital gain fromfor the business year; and when there is any amount that has been included in gross profits, with regard to the transfer of land, etc., and any other matters specified by Order of pursuant to the provisions of Article 64-2, paragraphs (9) through (12) (including the Ministry case where these provisions are applied mutatis mutandis pursuant to Article 65, paragraph (3)), Article 65-7, paragraph (4) (including the case where it is applied mutatis mutandis pursuant to Article 65-8, paragraph (14)), Article 65-7, paragraph (12) (including the case where it is applied mutatis mutandis pursuant to Article 65-8, paragraph (15)), or Article 65-8, paragraphs (9) through (12), the amount equivalent to the included amount is to be added to the amount of Financecapital gain for the business year.

With regard to the application of theThe provisions of Article 67 of the Corporation Tax Actparagraph (5) apply only in the case where the provisions of paragraph (1) or paragraph (9) apply,tax return, etc. has attached thereto the term "paragraphs (1), (2), and (6)document specified by Order of the preceding Article, and Article 69, paragraph (19) (Foreign Tax Credit) (including as applied mutatis mutandis pursuant to paragraph (23) ofMinistry of Finance that certifies that Article; the same applies in paragraph (3))" in paragraph (1)transfer of land, etc. falls under the category of the Article is deemed to be replaced with "Article 62-3, paragraphs (1) and (9) (Special Tax Rate for the Transfer of Land) ofa transfer for a determined site for constructing a superior residential area, etc. as prescribed in that paragraph and a document stating the Act on Special Measures Concerning Taxation", andamount specified by Cabinet Order as the term "paragraphs (1), (2), and (6) of the preceding Articleamount of capital gain from the transfer of land, etc., and Article 69, paragraph (19)" in paragraph (3)any other matters specified by Order of the Article is deemed to be replaced with "Article 62-3, paragraphs (1) and (9)Ministry of the Act on Special Measures Concerning Taxation"Finance.

The With regard to the application of the provisions of Article 62, paragraph (7) apply mutatis mutandis 67 of the Corporation Tax Act in the case where the provisions of paragraph (1) or paragraph (910) apply. In this case, , the term "paragraphs (1), (2), and (6) of the phrase "preceding Article, and the provisions of Article 69, paragraph (19) (Foreign Tax Credit) (including as applied mutatis mutandis pursuant to paragraph (1)" in 23) of that Article 62, ; the same applies in paragraph (7), item (i) 3))" in paragraph (1) of the Article is deemed to be replaced with "Article 62-3, paragraphs (1) and (10) (Special Tax Rate for the provisionsTransfer of Land) of the Act on Special Measures Concerning Taxation", and the term "paragraphs (1), (2), and (6) of the preceding Article , and Article 69, paragraph (19)" in paragraph (3) of the Article is deemed to be replaced with "Article 62-3, paragraphs (1) and (9)10) of the Act on Special Measures Concerning Taxation".

Beyond what is provided for in the preceding three paragraphs, matters concerning the application of The provisions of Article 62, paragraph (7) apply mutatis mutandis where the provisions of the Corporation Tax Act and other laws and regulations related to the corporation tax, to filing of returns or refunds of corporation tax, paragraph (1) or paragraph (10) apply. In this case, the phrase "and of the provisions of the Local Corporation Tax Act and other laws and regulations related to the local corporation tax, to filing of returns or refunds of local corporation tax, paragraph (1)" in Article 62, paragraph (7), item (i) is deemed to be replaced with "and other necessary matters concerning the application of the provisions of paragraph (1), paragraph (5) or paragraph (9) are specified by Cabinet OrderArticle 62-3, paragraphs (1) and (10)".

The Beyond what is provided for in the preceding three paragraphs, matters concerning the application of the provisions of paragraph (1) do not apply the Corporation Tax Act and other laws and regulations related to a transfer, etc. the corporation tax, to filing of land that a returns or refunds of corporation has made duringtax, and of the period from January 1, 1998 through March 31, 2029provisions of the Local Corporation Tax Act and other laws and regulations related to the local corporation tax, to filing of returns or refunds of local corporation tax, and other necessary matters concerning the application of the provisions of paragraph (1), paragraph (5) or paragraph (10) are specified by Cabinet Order.

The provisions of paragraph (1) do not apply to a transfer, etc. of land that a corporation has made during the period from January 1, 1998 through March 31, 2029.

Where a corporation has made a transfer, etc. of land held for a short term, the amount of corporation tax to be imposed on the corporation on its income for each business year is to be, notwithstanding the provisions of Article 66, paragraphs (1) through (3) and paragraph (6), Article 69, paragraph (19) (including as applied mutatis mutandis pursuant to paragraph (23) or paragraph (24) of that Article), and Article 143, paragraph (1) and paragraph (2) of the Corporation Tax Act, the provisions of Article 42-4, paragraph (8), item (vi), (b) and item (vii) (including as applied mutatis mutandis pursuant to Article 42-4-2, paragraph (2) or Article 42-5, paragraph (3), item (ii)), Article 42-14, paragraph (1) and paragraph (4), Article 62, paragraph (1), paragraph (1) and paragraph (910) of the preceding Article, Article 67-2, paragraph (1), and Article 68, paragraph (1), and the provisions of other corporation tax-related laws and regulations, the sum of the amount of corporation tax calculated pursuant to these provisions plus the amount obtained by multiplying the total of the amount of capital gain from the transfer, etc. of land held for a short term by the rate of 10 percent.

The provisions of paragraph (1011) of the preceding Article apply mutatis mutandis where a corporation has made a transfer of land, etc. that falls under a transfer, etc. of land held for a short term (excluding a transfer of land, etc. falling under the provisions of the preceding paragraph) and the provisions of paragraph (1) are applied. In this case, the phrase "or Articles 65-7 through 66" in paragraph (1011) of that Article is deemed to be replaced with ", Article 65-10, or Article 66", and the phrase "Article 64-2, paragraphs (9) through (12) (including the case where these provisions are applied mutatis mutandis pursuant to Article 65, paragraph (3)), Article 65-7, paragraph (4) (including the case where it is applied mutatis mutandis pursuant to Article 65-8, paragraph (14)), Article 65-7, paragraph (12) (including the case where it is applied mutatis mutandis pursuant to Article 65-8, paragraph (15)), or Article 65-8, paragraphs (9) through (12)" is deemed to be replaced with "Article 64-2, paragraphs (9) through (12) (including the case where these provisions are applied mutatis mutandis pursuant to Article 65, paragraph (3))".