①In the case where a person specified by Cabinet Order as an individual who had held specified business assets (excluding a person who has already made a gift to which the provisions of this paragraph apply; referred to as the "donor" in this Article and the following Article) has made a gift to a special business donee of all of the specified business assets relating to the donor's business (excluding, in the case where all or part of those specified business assets belong to the co-ownership of two or more persons, the part relating to the shares of co-ownership held by persons other than that donor) (limited to a gift made during the period from January 1, 2019 to December 31, 2028 that is the first gift to which the provisions of this paragraph apply or a gift made by the day on which one year has elapsed from the day of that gift or any other day specified by Cabinet Order), then, with regard to the gift tax equivalent to the gift tax subject to deferral relating to the specified business assets for which a statement is made in the gift tax return that the special business donee seeks the application of the provisions of this paragraph (referred to as "special gifted business assets" in this Article and the following Article), out of the amount of gift tax for the year that includes the day of that gift that the special business donee must pay by filing the gift tax return (meaning the return filed by the due date under the provisions of Article 28, paragraph (1) of the Inheritance Tax Act; the same applies hereinafter in this Article), notwithstanding the provisions of Article 33 of that Act, a grace period is granted for the payment of that tax until the day of the death of that donor (or, with regard to the gift tax equivalent to the gift tax subject to deferral relating to special gifted business assets in the case where those special gifted business assets are ones relating to the application to that donor of the provisions of paragraph (14) (limited to the part relating to item (iii)), the person who made the gift of the specified business assets relating to those special gifted business assets to the person specified by Cabinet Order as one who had received the application of the provisions of this paragraph; the same applies in paragraph (14)), only if the special business donee has provided security equivalent to that gift tax subject to deferral by the due date for filing the gift tax return for that year.

②In this Article, the meanings of the terms listed in the following items are as prescribed respectively in those items:

③In the case where the special business donee to whom the provisions of paragraph (1) apply, the special gifted business assets referred to in that paragraph or the business relating to those special gifted business assets has come to fall under any of the cases listed in the following items, notwithstanding the provisions of that paragraph, the deadline of the tax payment grace period under the provisions of that paragraph is the day on which two months have elapsed from the day specified in the relevant item:

④In the case where all or part of the special gifted business assets to which the provisions of paragraph (1) apply have ceased to be used for the business of the special business donee (excluding the cases listed in the items of the preceding paragraph and the case specified by Cabinet Order as a case where it has become difficult to use them for that business), notwithstanding the provisions of paragraph (1), the deadline of the tax payment grace period under the provisions of that paragraph for the gift tax equivalent to the amount calculated pursuant to the provisions of Cabinet Order as the amount of the part corresponding to the part that has ceased to be used for that business, out of the gift tax subject to deferral (excluding, in the case where the provisions of this paragraph have already been applied, the amount calculated pursuant to the provisions of Cabinet Order as the amount corresponding to the value of the special gifted business assets to which the provisions of this paragraph have been applied; referred to as the "amount of gift tax under a grace period" hereinafter in this Article and in paragraph (1) of the following Article), is the day on which two months have elapsed from the day on which they ceased to be used for that business.

⑤In the case referred to in the preceding paragraph, where the reason for which the assets ceased to be used for the business referred to in that paragraph is a transfer of special gifted business assets, if approval has been obtained from the district director with jurisdiction over the place for tax payment, pursuant to the provisions of Cabinet Order, for the expectation that, within one year from the day on which that transfer took place, assets to be used for the business of the special business donee (limited to the assets listed in paragraph (2), item (i), (a) or (b) or the assets specified in (c) of that item) will be acquired with all or part of the amount of consideration for that transfer, the following provisions apply with regard to the application of the provisions of the preceding paragraph:

⑥In the case referred to in paragraph (4), where the reason for which the assets ceased to be used for the business referred to in that paragraph is a transfer of all of the special gifted business assets through a capital contribution in kind upon the incorporation of a company after the day on which five years have elapsed from the day following the specified return due date (meaning the due date for filing the gift tax return for the year that includes the day of the first gift to which the provisions of paragraph (1) apply received by the special business donee to whom the provisions of that paragraph apply, or the due date for filing the inheritance tax return prescribed in Article 70-6-10, paragraph (1) relating to the first inheritance to which the provisions of that paragraph apply, whichever is earlier; the same applies in paragraph (9) and paragraph (14), item (iii)), if approval has been obtained from the district director with jurisdiction over the place for tax payment, pursuant to the provisions of Cabinet Order, for that transfer of the special gifted business assets, then, with regard to the application of the provisions of paragraph (4), the transfer relating to that approval is deemed not to have taken place, and the shares or equity interests acquired through that capital contribution in kind are deemed to be special gifted business assets to which the provisions of paragraph (1) apply (including, in the case where that company has been extinguished through a merger or in any other case specified by Order of the Ministry of Finance, those specified by Order of the Ministry of Finance as equivalent to the shares or equity interests of that company). In this case, necessary matters concerning the application of the provisions of paragraphs (3), (4), (14) and (16) through (18) after that approval has been obtained are specified by Cabinet Order.

⑦The provisions of paragraph (1) do not apply to specified business assets acquired by gift from the donor if, with regard to assets used for the same business as the business relating to those specified business assets, there is another special business donee who is receiving the application of the provisions of that paragraph, another special business donee who seeks to receive the application of the provisions of that paragraph, or another special business heir, etc. prescribed in Article 70-6-10, paragraph (2), item (ii) who is receiving the application of the provisions of paragraph (1) of that Article.

⑧The provisions of paragraph (1) do not apply in the case where the gift tax return relating to the assets used for business that the special business donee seeking the application of the provisions of that paragraph acquired by gift from the donor does not state that the special business donee seeks the application of the provisions of that paragraph for all or part of those assets, or where a document stating details of those assets, details concerning the calculation of the gift tax subject to deferral and other matters specified by Order of the Ministry of Finance is not attached to that return.

⑨If, during the period from the day following the due date for filing the gift tax return for the year that includes the day of the gift to which the provisions of paragraph (1) apply until the day on which the deadline of the tax payment grace period under the provisions of that paragraph, paragraph (3), paragraph (4), paragraph (11) or paragraph (12) is fixed for all of the gift tax equivalent to the amount of gift tax under a grace period, there is a special gift report base date (meaning each day on which a period of three years elapses from the day following the specified return due date), the special business donee to whom the provisions of paragraph (1) apply must, by the notification deadline (meaning the day on which three months have elapsed from the day following that special gift report base date; the same applies in the following paragraph, paragraph (11) and paragraph (15)), submit to the district director with jurisdiction over the place for tax payment, pursuant to the provisions of Cabinet Order, a written notification stating that the special business donee wishes to continue to receive the application of the provisions of paragraph (1) and matters concerning the business relating to the special gifted business assets referred to in that paragraph.

⑩With regard to the prescription of the national government's right to collect the gift tax equivalent to the amount of gift tax under a grace period and the interest tax and delinquent tax relating to that gift tax, except in the case where the provisions of Article 73, paragraph (4) of the Act on General Rules for National Taxes as applied by replacing terms pursuant to paragraph (13), item (iii) apply, the prescription is not completed during the period from the time of submission of the written notification referred to in the preceding paragraph until the notification deadline of that written notification, and is to begin to run anew from the day following that notification deadline.

⑪In the case where the written notification referred to in paragraph (9) is not submitted to the district director with jurisdiction over the place for tax payment by the notification deadline, notwithstanding the provisions of paragraph (1), the deadline of the tax payment grace period under the provisions of that paragraph for the gift tax equivalent to the amount of gift tax under a grace period as of that notification deadline is the day on which two months have elapsed from the day following that notification deadline.

⑫In the following cases, the district director may accelerate the deadline of the tax payment grace period under the provisions of paragraph (1) relating to the gift tax equivalent to the amount of gift tax under a grace period. In this case, the provisions of Article 49, paragraphs (2) and (3) of the Act on General Rules for National Taxes apply mutatis mutandis:

⑬With regard to the application of the provisions of the Act on General Rules for National Taxes, the National Tax Collection Act and the Inheritance Tax Act in the case where a special business donee seeks the application of the provisions of paragraph (1) or a tax payment grace period has been granted under the provisions of that paragraph, the following provisions apply:

⑭In the case where the special business donee to whom the provisions of paragraph (1) apply or the donor relating to that special business donee has come to fall under any of the cases listed in the following items (excluding the case where, before the day on which they came to fall under that case, the deadline of the tax payment grace period under the provisions of paragraph (3), paragraph (4), paragraph (11) or paragraph (12) has been fixed for all of the gift tax equivalent to the amount of gift tax under a grace period), the gift tax specified in each of those items is exempted. In this case, the special business donee or the heir of the special business donee (including a universal legatee; the same applies in paragraph (26)) must, during the period from the day on which they came to fall under that case until the day on which six months have elapsed from that day (or, in the case where they have come to fall under the case listed in item (iii), from the day on which the person who received the gift of the special gifted business assets referred to in that item filed the gift tax return to which the provisions of paragraph (1) apply with regard to those special gifted business assets) (referred to as the "deadline for notification of exemption" in the following paragraph), submit to the district director with jurisdiction over the place for tax payment, pursuant to the provisions of Cabinet Order, a written notification stating the matters specified by Order of the Ministry of Finance.

⑮Even in the case where the written notification referred to in paragraph (9) or the preceding paragraph has not been submitted by the notification deadline or the deadline for notification of exemption, if the district director prescribed in those provisions finds that there were unavoidable circumstances for the failure to submit it within those time limits and that written notification has been submitted to that district director pursuant to the provisions of Cabinet Order, that written notification is deemed to have been submitted within those time limits with regard to the application of the provisions of paragraph (11) or the preceding paragraph.

⑯In the case where the special business donee to whom the provisions of paragraph (1) apply has come to fall under any of the cases listed in the following items (excluding the case where, before the day on which the special business donee came to fall under that case, the deadline of the tax payment grace period under the provisions of paragraph (3), paragraph (4), paragraph (11) or paragraph (12) has been fixed for all of the gift tax equivalent to the amount of gift tax under a grace period), if the special business donee seeks an exemption from the gift tax specified in the relevant item, the special business donee must, by the day on which two months have elapsed from the day on which the special business donee came to fall under that case, submit to the district director with jurisdiction over the place for tax payment a written application stating that the special business donee wishes to receive that exemption, the amount equivalent to the gift tax for which the special business donee seeks that exemption (referred to as the "amount of gift tax applied for exemption" in paragraph (22)), details of its calculation and other matters specified by Order of the Ministry of Finance (limited to a written application to which the documents specified by Order of the Ministry of Finance as documents necessary for the procedure for that exemption are attached):

⑰In the case where the special business donee to whom the provisions of paragraph (1) apply has come to fall under any of the cases listed in the following items (limited to the case where a reason specified by Cabinet Order as a reason making it difficult for the special business donee to continue the business relating to the special gifted business assets has arisen, and excluding the case where, before the day on which the special business donee came to fall under that case, the deadline of the tax payment grace period under the provisions of paragraph (3), paragraph (4), paragraph (11) or paragraph (12) has been fixed for all of the gift tax equivalent to the amount of gift tax under a grace period), if the special business donee seeks an exemption from the gift tax specified in the relevant item, the special business donee must, by the day on which two months have elapsed from the day on which the special business donee came to fall under that case, submit to the district director with jurisdiction over the place for tax payment a written application stating that the special business donee wishes to receive that exemption, the amount equivalent to the gift tax for which the special business donee seeks that exemption (referred to as the "amount of gift tax applied for exemption" in paragraph (22)), details of its calculation and other matters specified by Order of the Ministry of Finance (limited to a written application to which the documents specified by Order of the Ministry of Finance as documents necessary for the procedure for that exemption are attached):

⑱In the case where a confirmation order for a rehabilitation plan under the provisions of the Civil Rehabilitation Act has been issued with regard to the special business donee referred to in paragraph (1) (including the case where a fact specified by Cabinet Order as equivalent to a confirmation order for a rehabilitation plan has occurred), when an assessment specified by Cabinet Order has been made of the assets held by the special business donee (excluding the case where, on or after the day on which that confirmation order was issued (or, in the case where the fact specified by that Cabinet Order has occurred, the day on which the debt workout plan was formed; referred to as the "date of the confirmation order" hereinafter through paragraph (20)) and before the day on which the notice under the provisions of paragraph (21) is issued, the deadline of the tax payment grace period under the provisions of paragraph (3), paragraph (4), paragraph (11) or paragraph (12) has been fixed for all of the gift tax equivalent to the amount of gift tax under a grace period, and limited, for a special business donee who is performing a rehabilitation plan, to the case where a supervisor or trustee has been appointed), the recalculated deferred gift tax is to be the amount of gift tax under a grace period relating to the special gifted business assets. In this case, notwithstanding the provisions of paragraph (1), the deadline of the tax payment grace period under the provisions of that paragraph for the gift tax equivalent to the amount listed in item (ii) is the day on which two months have elapsed from the day on which that notice is issued, and the gift tax equivalent to the remaining amount after deducting the sum of the following amounts from the amount of gift tax under a grace period (referred to as "gift tax exempted on recalculation" in paragraph (21)) is exempted:

⑲The term "recalculated deferred gift tax" referred to in the preceding paragraph means the amount calculated under the provisions of paragraph (2), item (iii) by deeming the value, as of the date of the confirmation order, of the special gifted business assets to which the provisions of paragraph (1) apply (limited to the part corresponding to the amount of gift tax under a grace period) to be the value, at the time of the gift, of the special gifted business assets acquired through the gift to which the provisions of that paragraph apply.

⑳The provisions of paragraph (18) apply only in the case where the special business donee seeking the application of the provisions of that paragraph has, by the day on which two months have elapsed from the date of the confirmation order, submitted to the district director with jurisdiction over the place for tax payment a written application stating that the special business donee wishes to receive the application of the provisions of that paragraph, the recalculated deferred gift tax prescribed in the preceding paragraph, details of its calculation and other matters specified by Order of the Ministry of Finance (limited to a written application to which the documents specified by Order of the Ministry of Finance as documents concerning the rehabilitation plan (including a debt workout plan) for which the confirmation order prescribed in paragraph (18) was issued are attached).

（二十一）In the case where a written application under the provisions of paragraph (16), paragraph (17) or the preceding paragraph has been submitted, the district director conducts an investigation into the matters stated in that written application, and either grants an exemption from the gift tax specified in the relevant item of paragraph (16) or paragraph (17) according to the category of the cases listed in those items or from the gift tax exempted on recalculation, or dismisses the application relating to that written application. In this case, the district director is to notify the special business donee who submitted that written application of the amount of the gift tax so exempted or the amount of that gift tax exempted on recalculation, or of the dismissal and the reason therefor, by means of a document stating them, within six months counting from the day following the deadline for the application relating to that written application.

（二十二）If the district director, in the case where the written application referred to in paragraph (16) or paragraph (17) has been submitted, finds that there are reasonable grounds, the district director may grant a grace period for the collection of the gift tax equivalent to the amount of gift tax applied for exemption relating to that application, during the period from the due date for payment relating to that written application (meaning the day listed in the right-hand column of item (v) or item (vi) of the table in paragraph (25), according to the category of the cases listed in the left-hand column of item (v) or item (vi) of that table) or the day on which that written application was submitted, whichever is later, until the day on which one month has elapsed on or after the day following the day on which the notice under the provisions of the preceding paragraph was issued.

（二十三）In the case where a special business donee receives the application of the provisions of paragraph (16), item (i) or paragraph (17), item (i) or (ii), if the district director finds that there is an unavoidable reason for the special business donee's being unable to determine the appropriate market value, the district director may grant an exemption from the amount of the part of the delinquent tax on the gift tax that has become payable as a result of coming to fall under the case listed in the left-hand column of item (v) or item (vi) of the table in paragraph (25) that corresponds to the period from the day following the due date for payment prescribed in the preceding paragraph until the day on which one month has elapsed on or after the day following the day on which the notice under the provisions of paragraph (21) was issued.

（二十四）Beyond what is provided for in paragraph (20) through the preceding paragraph, necessary matters concerning the application of the provisions of paragraphs (16) through (18) are specified by Cabinet Order.

（二十六）In the case where, by the deadline of the tax payment grace period prescribed in paragraph (3), paragraph (4), paragraph (11) or paragraph (18), the due date for submitting the written application prescribed in paragraph (16), paragraph (17) or paragraph (20), the due date for payment prescribed in paragraph (22), or the end of the period forming the basis for calculating the interest tax prescribed in the preceding paragraph (limited to the interest tax relating to item (v) or item (vi) of the table in that paragraph), the special business donee prescribed in those provisions has died, notwithstanding those provisions, the deadline of the tax payment grace period, the due date for submitting the written application, the due date for payment or the end of the period forming the basis for calculating the interest tax prescribed in those provisions is, respectively, the day on which six months have elapsed from the day following the day on which the heir of that special business donee came to know of the commencement of the succession due to the death of that special business donee.

（二十七）The Minister of Economy, Trade and Industry or the Director-General of a Bureau of Economy, Trade and Industry (or, in the case where the special certification for business succession is to be made by a prefectural governor pursuant to the provisions of a Cabinet Order based on the provisions of Article 17 of the Act on Facilitation of Succession of Management of Small and Medium Sized Enterprises, that prefectural governor; the same applies in the following paragraph and in Article 70-6-10, paragraphs (28) and (29)) must, if any of them has come to know, as a result of having made a certification or confirmation, accepted a report or taken any other action based on the provisions of laws and regulations with regard to a fact relating to the fixing of the deadline of the tax payment grace period under the provisions of paragraph (3) or paragraph (4) with respect to the special business donee to whom the provisions of paragraph (1) apply, the special gifted business assets referred to in that paragraph or the business relating to those special gifted business assets, that the fact has occurred, notify the Commissioner of the National Tax Agency or the district director with jurisdiction over the place for tax payment of that special business donee in writing, without delay, that the fact has occurred with regard to that business and of other matters specified by Order of the Ministry of Finance.

（二十八）If the district director, in the case referred to in paragraph (1), finds it necessary for the proper and reliable handling of the affairs of the Minister of Economy, Trade and Industry or the Director-General of a Bureau of Economy, Trade and Industry (limited to affairs concerning the special business donee to whom the provisions of that paragraph apply that relate to the application of the provisions of the preceding paragraph), the district director may notify the Minister of Economy, Trade and Industry or the Director-General of a Bureau of Economy, Trade and Industry that the special business donee receives the application of the provisions of paragraph (1), and of other matters specified by Order of the Ministry of Finance.

（二十九）Beyond what is provided for in paragraph (3) through the preceding paragraph, necessary matters concerning the application of paragraph (1) are specified by Cabinet Order.