一certified succession company: a company that has received the management succession certification, among small and medium sized enterprises prescribed in Article 2 of the Act on Facilitation of Succession of Management of Small and Medium Sized Enterprises (or, 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, an entity specified by Order of the Ministry of Finance as equivalent to that company), that satisfies all of the following requirements as of the time of commencement of the succession to which the provisions of the preceding paragraph apply:

イthe number of regular employees (meaning those specified by Order of the Ministry of Finance as employees who are regularly employed; the same applies hereinafter in this Article) of the company is one or more;

ロthe company does not fall under the category of an asset-holding company or asset-management company specified by Cabinet Order;

ハthe shares, etc. (meaning shares or capital contributions; the same applies hereinafter in this Article) of the company (referred to as the "specified company" in (c)) and the shares, etc. of a company specified by Cabinet Order as a company that has a close relationship with the specified company (referred to as a "specified specially related company" in (d) and in item (xvi) of the following paragraph), among specially related companies (meaning companies that have a special relationship specified by Cabinet Order with the specified company; the same applies hereinafter in this paragraph and in paragraph (14), item (xi)), fall under the category of unlisted shares or similar interests;

ニthe company and specified specially related companies do not fall under the category of a sex-related business company prescribed in paragraph (2), item (i), (d) of the preceding Article;

ホin the case where a specially related company of the company falls under the category of a foreign company prescribed in Article 2, item (ii) of the Companies Act (limited to the case where the company or a corporation that has a controlling relationship with the company holds shares, etc. of that specially related company), the number of regular employees of the company is five or more;

ヘbeyond what is listed in (a) through (e), the company satisfies the requirements specified by Cabinet Order as requirements necessary for ensuring the smooth operation of the business of a company.

二unlisted shares or similar interests: the shares, etc. specified in paragraph (2), item (ii) of the preceding Article;

四management succession certification: the certification specified in paragraph (2), item (iv) of the preceding Article;

五inheritance tax subject to deferral: the remaining amount after deducting the amount listed in (b) from the amount listed in (a);

イthe amount of inheritance tax of the successor heir, etc. calculated pursuant to the provisions of Cabinet Order by applying the provisions of Articles 13 through 19 of the Inheritance Tax Act, deeming the value of the covered unlisted shares or similar interests to which the provisions of the preceding paragraph apply (or, in the case where the certified succession company relating to those covered unlisted shares or similar interests, or a specially related company of that certified succession company that is a corporation having a controlling relationship with that certified succession company (referred to as a "certified succession company, etc." in (a)), holds shares, etc. (including investment equity prescribed in Article 2, paragraph (14) of the Act on Investment Trusts and Investment Corporations) of a foreign company prescribed in Article 2, item (ii) of the Companies Act (limited to one that falls under the category of a specially related company of that certified succession company) or of any other corporation specified by Cabinet Order, the value calculated on the assumption that the certified succession company, etc. did not hold those shares, etc.; the same applies in (b)) to be the taxable value of inheritance tax relating to the successor heir, etc. referred to in the preceding paragraph;

ロthe amount of inheritance tax of the successor heir, etc. calculated pursuant to the provisions of Cabinet Order by applying the provisions of Articles 13 through 19 of the Inheritance Tax Act, deeming the amount calculated by multiplying the value of the covered unlisted shares or similar interests to which the provisions of the preceding paragraph apply by 20 percent to be the taxable value of inheritance tax relating to the successor heir, etc. referred to in that paragraph.

六business succession period: the period from the day following the due date for filing the inheritance tax return relating to the succession to which the provisions of the preceding paragraph apply until the earlier of the following days, or the day preceding the day of the death of the successor heir, etc. relating to that succession, whichever is earlier;

イthe day on which five years have elapsed on or after the day following the due date for filing the inheritance tax return relating to the first succession of the successor heir, etc. to which the provisions of the preceding paragraph apply;

ロthe day on which five years have elapsed on or after the day following the due date for filing the gift tax return prescribed in paragraph (1) of the preceding Article for the year that includes the day of the first gift of the successor heir, etc. to which the provisions of that paragraph apply.

七base date for management reports: the day specified in (a) or (b) below according to the category of the periods listed in (a) or (b);

イthe business succession period: each day on which one year elapses from the day following the due date for filing the inheritance tax return relating to the succession to which the provisions of the preceding paragraph apply (or, in the case where, before receiving the application of the provisions of that paragraph, the successor heir, etc. has received the application of the provisions of paragraph (1) of the preceding Article with regard to the unlisted shares or similar interests of the certified succession company relating to the covered unlisted shares or similar interests referred to in the preceding paragraph, the due date for filing the gift tax return prescribed in paragraph (1) of the preceding Article) (referred to as a "type 1 base date" in paragraph (10));

ロthe period from the day following the last day of the business succession period until the day on which the deadline of the tax payment grace period under the provisions of the preceding paragraph, the following paragraph through paragraph (5), paragraph (12), paragraph (13) or paragraph (15) is fixed for all of the inheritance tax equivalent to the inheritance tax subject to deferral (excluding, in the case where the provisions of paragraph (4) or paragraph (5) have already been applied, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the part corresponding to the value of the covered unlisted shares or similar interests to which those provisions have been applied; referred to as the "amount of inheritance tax under a grace period" hereinafter in this Article): each day on which three years elapse from the day following that last day (referred to as a "type 2 base date" in paragraph (10)).

八asset-holding company: the company specified in paragraph (2), item (viii) of the preceding Article;

九asset-management company: the company specified in paragraph (2), item (ix) of the preceding Article.

一in the case where the successor heir, etc. has ceased to have the authority of representation of the certified succession company relating to the covered unlisted shares or similar interests held by the successor heir, etc. (excluding the case where there is an unavoidable reason specified by Order of the Ministry of Finance for having ceased to have that authority of representation): the day on which the successor heir, etc. ceased to have it;

二in the case where the number calculated by dividing the total number of regular employees of the certified succession company relating to the covered unlisted shares or similar interests as of each base date (meaning each day on which one year elapses from the day following that filing deadline; the same applies hereinafter in this item and in item (ii), (a) of that paragraph) falling within the employee number confirmation period (meaning the period from the day following the filing deadline of the first inheritance tax return, or of the gift tax return prescribed in paragraph (1) of the preceding Article, that is filed in order to receive the application of the provisions of paragraph (1) of this Article or paragraph (1) of the preceding Article with regard to the unlisted shares or similar interests of the certified succession company relating to the covered unlisted shares or similar interests, until the day on which five years have elapsed on or after that day (or, in the case where the successor heir, etc. has died by that day, the day preceding the day of that death); the same applies hereinafter in this item and in paragraph (31), item (ii), (a)) by the number of base dates falling within the employee number confirmation period, as of the last day of the employee number confirmation period, has fallen below the number specified by Cabinet Order as the number at which the employment of those regular employees is deemed to be secured: the last day of the employee number confirmation period;

三in the case where the total number of voting rights held by the successor heir, etc. and persons who have a special relationship specified by Cabinet Order with the successor heir, etc. (limited to voting rights relating to the unlisted shares or similar interests of the certified succession company relating to the covered unlisted shares or similar interests) has become 50 percent or less of the total number of voting rights of all shareholders, etc. of the certified succession company (excluding the case where, in the case where the successor heir, etc. has ceased to have the authority of representation of the certified succession company relating to the covered unlisted shares or similar interests held by the successor heir, etc. (limited to the case where there is an unavoidable reason specified by Order of the Ministry of Finance prescribed in item (i); the same applies in the left-hand column of item (i) of the table in the following paragraph and in paragraph (16), item (ii)), the successor heir, etc. has made a gift to which the provisions of paragraph (1) of the preceding Article or Article 70-7-5, paragraph (1) apply (including a gift of the eligible unlisted shares, etc. made together with that gift; the same applies in item (i) of that table) of the covered unlisted shares or similar interests (including covered unlisted shares or similar interests relating to the certified succession company other than those covered unlisted shares or similar interests, and covered gifted unlisted shares or similar interests prescribed in paragraph (1) of the preceding Article or covered inherited unlisted shares or similar interests prescribed in Article 70-7-4, paragraph (1) relating to the certified succession company; referred to as "eligible unlisted shares, etc." in this item and in items (v) and (vi)); the same applies in the following item and in item (v)): the day on which it became 50 percent or less;

四in the case where any of the persons who have a special relationship specified by Cabinet Order prescribed in the preceding item with the successor heir, etc. has come to hold voting rights relating to the unlisted shares or similar interests of the certified succession company relating to the covered unlisted shares or similar interests held by the successor heir, etc. in a number exceeding the number of voting rights relating to those unlisted shares or similar interests held by the successor heir, etc.: the day on which that person came to hold them;

五in the case where the successor heir, etc. has made a transfer or gift (referred to as a "transfer, etc." hereinafter in this Article) of part of the eligible unlisted shares, etc.: the day on which that transfer, etc. was made;

六in the case where the successor heir, etc. has made a transfer, etc. of all of the eligible unlisted shares, etc. (excluding the case where the certified succession company relating to the eligible unlisted shares, etc. has become a wholly owned subsidiary company resulting from a share exchange or share transfer (meaning a wholly owned subsidiary company resulting from the share exchange prescribed in Article 768, paragraph (1), item (i) of the Companies Act or a wholly owned subsidiary company resulting from a share transfer prescribed in Article 773, paragraph (1), item (v) of that Act; the same applies hereinafter in this Article) of another company through a share exchange or share transfer (referred to as a "share exchange, etc." hereinafter in this Article)): the day on which that transfer, etc. was made;

七in the case listed in the left-hand column of item (v) or in the left-hand column of item (vi) of the table in paragraph (5): the day listed in the right-hand column of item (v) or in the right-hand column of item (vi) of that table, respectively;

八in the case where the certified succession company relating to the covered unlisted shares or similar interests has dissolved (excluding the case where it is extinguished through a merger) or has been deemed to have dissolved pursuant to the provisions of the Companies Act or any other Act: the day of that dissolution or the day of that deemed dissolution;

九in the case where the certified succession company relating to the covered unlisted shares or similar interests has come to fall under the category of an asset-holding company or asset-management company specified by Cabinet Order: the day on which it came to fall under that category;

十in the case where the gross revenue (limited to the revenue specified by Order of the Ministry of Finance as what is to be treated as the amount of revenue arising from its principal business activities) of the certified succession company relating to the covered unlisted shares or similar interests in a business year has become zero: the end of that business year;

十一in the case where the certified succession company relating to the covered unlisted shares or similar interests has reduced the amount of its stated capital pursuant to the provisions of Article 447, paragraph (1) or Article 626, paragraph (1) of the Companies Act, or has reduced the amount of its reserves pursuant to the provisions of Article 448, paragraph (1) of that Act (excluding the case falling under Article 309, paragraph (2), item (ix), (a) and (b) of that Act and any other case specified by Order of the Ministry of Finance as being similar thereto): the day on which that reduction of the amount of stated capital or that reduction of the amount of reserves became effective;

十二in the case where the successor heir, etc. has submitted to the district director with jurisdiction over the place for tax payment a written notification stating that the successor heir, etc. will cease to receive the application of the provisions of paragraph (1): the day on which that written notification was submitted;

十三in the case where the certified succession company relating to the covered unlisted shares or similar interests has been extinguished through a merger (excluding the case specified by Order of the Ministry of Finance as a case where an entity equivalent to the certified succession company exists as a result of that merger (referred to as the "case where it has carried out a qualified merger" in the left-hand column of item (ii) of the table in the following paragraph)): the day on which that merger became effective;

十四in the case where the certified succession company relating to the covered unlisted shares or similar interests has become a wholly owned subsidiary company resulting from a share exchange or share transfer of another company through a share exchange, etc. (excluding the case specified by Order of the Ministry of Finance as a case where an entity equivalent to the certified succession company exists as a result of that share exchange, etc. (referred to as the "case where it has carried out a qualified share exchange, etc." in the left-hand column of item (ii) of the table in the following paragraph)): the day on which that share exchange, etc. became effective;

十五in the case where the shares, etc. of the certified succession company relating to the covered unlisted shares or similar interests have ceased to fall under the category of unlisted shares or similar interests: the day on which they ceased to fall under that category;

十六in the case where the certified succession company relating to the covered unlisted shares or similar interests or a specified specially related company of the certified succession company has come to fall under the category of a sex-related business company prescribed in paragraph (2), item (i), (d) of the preceding Article: the day on which it came to fall under that category;

十七beyond the cases listed in the preceding items, in the case specified by Cabinet Order as a case where there is a risk of hindering the smooth operation of the business of the certified succession company relating to the covered unlisted shares or similar interests by the successor heir, etc.: the day specified by Cabinet Order.

一in the case where the successor heir, etc. to whom the provisions of paragraph (1) apply does not comply, with regard to the security prescribed in that paragraph, with an order under the provisions of Article 51, paragraph (1) of the Act on General Rules for National Taxes;

二in the case where a fact has been found that differs from the matters stated in the written notification referred to in paragraph (10) submitted by the successor heir, etc.

一with regard to delinquent tax on inheritance tax in the case where the provisions of paragraph (1) have been applied, the amount of that inheritance tax is divided into the inheritance tax subject to deferral and the remainder, that inheritance tax subject to deferral is further divided according to each different deadline of the tax payment grace period prescribed in item (vi), and the provisions concerning delinquent tax in the Act on General Rules for National Taxes apply to each of those tax amounts;

二in the case where a successor heir, etc. seeking the application of the provisions of paragraph (1) provides all of the covered unlisted shares or similar interests as security pursuant to the provisions of the main clause of paragraph (6), the phrase "securities that the district director of the tax office, etc. (or, in the case where the Commissioner of the National Tax Agency or the regional commissioner is to collect security pursuant to the provisions of an Act concerning national taxes, the Commissioner of the National Tax Agency or the regional commissioner; the same applies hereinafter in this Article and the following Article) finds to be reliable" in Article 50, item (ii) of the Act on General Rules for National Taxes is deemed to be replaced with "securities and equity interests in a membership company (limited to those that satisfy the requirements specified by Order of the Ministry of Finance, such as not being the subject of a pledge or any other security interest)", and the provisions of Article 51, paragraph (1) of that Act do not apply;

三in the case referred to in the preceding item, when the provisions of the proviso to paragraph (6) apply, the provisions of that item do not apply;

四with regard to the application of the provisions of Articles 56 through 58 of the Act on General Rules for National Taxes to inheritance tax equivalent to the amount that has become an overpayment or erroneous payment as a result of the notice under the provisions of paragraph (18), the overpayment or erroneous payment is deemed to have been made on the day on which that notice was issued or the day on which six months have elapsed from the application deadline prescribed in paragraph (17), whichever is earlier;

五with regard to inheritance tax for which a tax payment grace period has been granted under the provisions of paragraph (1), the phrase "deferred payment" in Article 64, paragraph (1) and Article 73, paragraph (4) of the Act on General Rules for National Taxes is deemed to be replaced with "deferred payment (including a tax payment grace period under the provisions of Article 70-7-2, paragraph (1) (Tax Payment Grace Period and Exemption for Inheritance Tax on Unlisted Shares or Similar Interests) of the Act on Special Measures Concerning Taxation)";

六the deadline of the tax payment grace period under the provisions of paragraph (1) (including that deadline under the provisions of paragraphs (3) through (5), the preceding two paragraphs or the following paragraph) is to be included in the deadline for deferred payment under the provisions of the Inheritance Tax Act when the provisions concerning the statutory due date for payment or the due date for payment in the Act on General Rules for National Taxes and the National Tax Collection Act are applied;

七with regard to inheritance tax for which a tax payment grace period has been granted under the provisions of paragraph (1), the phrase "finds so, the district director of the tax office, etc." in Article 52, paragraph (4) of the Act on General Rules for National Taxes is deemed to be replaced with "finds so (or, in the case where shares of or capital contributions to the certified succession company referred to in Article 70-7-2, paragraph (1) (Tax Payment Grace Period and Exemption for Inheritance Tax on Unlisted Shares or Similar Interests) of the Act on Special Measures Concerning Taxation relating to the covered unlisted shares or similar interests prescribed in that paragraph have been provided as security for the tax payment grace period under the provisions of that paragraph, when it so finds, or when there is no buyer even if those shares or capital contributions are put up for realization), the district director of the tax office, etc."; and the phrase "property" in Article 48, paragraph (1) of the National Tax Collection Act is deemed to be replaced with "property (excluding, in the case where shares of or capital contributions to the certified succession company referred to in Article 70-7-2, paragraph (1) (Tax Payment Grace Period and Exemption for Inheritance Tax on Unlisted Shares or Similar Interests) of the Act on Special Measures Concerning Taxation relating to the covered unlisted shares or similar interests prescribed in that paragraph have been provided as security for the tax payment grace period under the provisions of that paragraph, other property of the successor heir, etc. prescribed in paragraph (2), item (iii) of that Article who provided that security, when there is no buyer even if those shares or capital contributions are put up for realization)";

八in the case where the written application referred to in paragraph (17) has been submitted, the inheritance tax equivalent to the amount of inheritance tax applied for exemption prescribed in that paragraph relating to that written application does not, with regard to the application of the provisions of Article 82, paragraph (1) of the National Tax Collection Act, fall under delinquent national tax referred to in paragraph (1) of that Article until the day on which the notice under the provisions of paragraph (18) is issued;

九the provisions of Article 38, paragraph (1) and Article 41, paragraph (1) of the Inheritance Tax Act do not apply to inheritance tax that falls under the provisions of paragraph (3) (excluding the part relating to item (ii) of that paragraph), paragraph (4), paragraph (5), the preceding two paragraphs or the following paragraph;

十with regard to inheritance tax equivalent to the inheritance tax subject to deferral that falls under the provisions of paragraph (3) (limited to the part relating to item (ii) of that paragraph), the provisions of Article 38, paragraph (1), Article 39, paragraph (1), Article 42, paragraph (1), Article 48-2, paragraph (2) and Article 52, paragraph (1) of the Inheritance Tax Act apply with the period of deferred payment under Article 38, paragraph (1) of that Act being within five years, with the due date for payment of inheritance tax for which deferred payment under Article 39, paragraph (1) of that Act is sought and the due date for payment of inheritance tax for which payment in kind under Article 42, paragraph (1) of that Act is sought being the day on which five months have elapsed from the last day of the business succession period (referred to as the "deadline for applying for deferred payment, etc." in this item), with the deadline for submitting a written application under the provisions of Article 48-2, paragraph (2) of that Act being the day on which five years have elapsed from the day following the deadline for applying for deferred payment, etc., and with the rate of interest tax under Article 52, paragraph (1) of that Act being 6.6 percent per annum. In this case, for the period from the day following the deadline of the tax payment grace period under the provisions of paragraph (1) (limited to that relating to paragraph (3), item (ii)) until the deadline for applying for deferred payment, etc., interest tax is to be paid in lieu of the part of the delinquent tax corresponding to that period (limited to the part relating to the portion of the amount of inheritance tax under a grace period for which permission for deferred payment or payment in kind has been granted), and the amount of interest tax to be paid is the amount calculated by multiplying the portion for which that permission has been granted, as the base, by the rate specified in (a) or (b) below for that period, according to the category of the cases listed therein;

イin the case where permission for deferred payment has been granted: 6.6 percent per annum;

ロin the case where permission for payment in kind has been granted: 7.3 percent per annum.

十一with regard to the amount of inheritance tax, other than the inheritance tax subject to deferral, relating to property acquired through inheritance or bequest by a person whose property so acquired includes property that falls under covered unlisted shares or similar interests, the provisions of Article 38, paragraph (1) (including as applied mutatis mutandis pursuant to Article 44, paragraph (2) of that Act), Article 47, paragraph (5), Article 52, paragraph (1) or Article 53, paragraph (4), item (ii), (b) of the Inheritance Tax Act apply by deeming the value of those covered unlisted shares or similar interests to be the value calculated by multiplying the value of those covered unlisted shares or similar interests by 20 percent (or, in the case where the certified succession company relating to those covered unlisted shares or similar interests, or a specially related company of that certified succession company that is a corporation having a controlling relationship with that certified succession company (referred to as a "certified succession company, etc." hereinafter in this item), holds shares, etc. (including investment equity prescribed in Article 2, paragraph (14) of the Act on Investment Trusts and Investment Corporations) of a foreign company prescribed in Article 2, item (ii) of the Companies Act (limited to one that falls under the category of a specially related company of that certified succession company) or of any other corporation specified by Cabinet Order, the sum of the value calculated by multiplying by 20 percent the value calculated on the assumption that the certified succession company, etc. did not hold those shares, etc., and the value of those shares, etc.);

十二with regard to the application of the provisions of Article 41, paragraph (2) of the Inheritance Tax Act as applied mutatis mutandis pursuant to Article 48-2, paragraph (6) of that Act in the case where the provisions of paragraph (1) have been applied to covered unlisted shares or similar interests, the phrase "excluding property" in that paragraph is deemed to be replaced with "excluding property, and covered unlisted shares or similar interests prescribed in Article 70-7-2, paragraph (1) (Tax Payment Grace Period and Exemption for Inheritance Tax on Unlisted Shares or Similar Interests) of the Act on Special Measures Concerning Taxation to which the provisions of that paragraph apply, other than those relating to the amount of inheritance tax under a grace period that falls under the provisions of paragraph (3) of that Article (limited to the part relating to item (ii) of that paragraph)".

一in the case where the successor heir, etc. has died: the inheritance tax equivalent to the amount of inheritance tax under a grace period;

二in the case where, on or after the day following the last day of the business succession period (or, in the case where the successor heir, etc. has ceased to have the authority of representation of the certified succession company relating to the covered unlisted shares or similar interests held by the successor heir, etc. within the business succession period, the day on which the successor heir, etc. ceased to have it), the successor heir, etc. has made a gift to which the provisions of paragraph (1) of the preceding Article or Article 70-7-5, paragraph (1) apply of covered unlisted shares or similar interests: the inheritance tax equivalent to the amount calculated pursuant to the provisions of Cabinet Order as the amount of the part, out of the amount of inheritance tax under a grace period, that corresponds to the covered unlisted shares or similar interests relating to that gift to which those provisions apply.

一in the case where, on or after the day following the last day of the business succession period, the successor heir, etc. has made a transfer, etc. of all of the unlisted shares or similar interests of the certified succession company relating to those covered unlisted shares or similar interests (limited to the case where it is made to a person specified by Cabinet Order as a single person among persons other than those who have a special relationship specified by Cabinet Order with the successor heir, etc., or the case where, when a confirmation order for a rehabilitation plan under the provisions of the Civil Rehabilitation Act or for a reorganization plan under the provisions of the Corporate Reorganization Act has been issued (including the case where a fact specified by Cabinet Order as equivalent to a confirmation order for a rehabilitation plan has occurred; the same applies in paragraph (33), item (i), (b)), it is made in order to cancel those unlisted shares or similar interests based on that rehabilitation plan or that reorganization plan (including a plan specified by Cabinet Order as a plan for the disposition of debts (referred to as a "debt workout plan" in paragraphs (22) and (24)); the same applies in (b) of that item), and excluding the case falling under the case listed in item (iv)), if the sum of the following amounts is less than the amount of inheritance tax under a grace period immediately before that transfer, etc.: the inheritance tax equivalent to the remaining amount after deducting that sum from that amount of inheritance tax under a grace period;

イthe amount specified by Order of the Ministry of Finance as the amount equivalent to the market value, at the time of that transfer, etc., of the covered unlisted shares or similar interests for which that transfer, etc. was made (or, in the case where the amount specified by that Order of the Ministry of Finance is lower than the amount of consideration for the transfer, etc. of the covered unlisted shares or similar interests for which that transfer, etc. was made, that amount of consideration for the transfer, etc.);

ロthe total of the amount of dividends of surplus, etc. that the successor heir, etc. and persons who share the same livelihood with the successor heir, etc. received from that certified succession company and other amounts specified by Cabinet Order as amounts received from that certified succession company, within five years on or before the day on which that transfer, etc. took place;

二in the case where, on or after the day following the last day of the business succession period, an order commencing bankruptcy proceedings or an order to commence special liquidation has been issued with regard to the certified succession company relating to those covered unlisted shares or similar interests: the inheritance tax equivalent to the remaining amount after deducting the amount listed in (b) from the amount listed in (a);

イthe amount of inheritance tax under a grace period immediately before the dissolution of that certified succession company (including the dissolution in the case where it is deemed to have dissolved pursuant to the provisions of the Companies Act or other laws; the same applies in (b) and in the right-hand column of item (vii) of the table in paragraph (28));

ロthe total of the amount of dividends of surplus, etc. that the successor heir, etc. and persons who share the same livelihood with the successor heir, etc. received from that certified succession company and other amounts specified by Cabinet Order as amounts received from that certified succession company, within five years before the dissolution of that certified succession company;

三in the case where, on or after the day following the last day of the business succession period, the certified succession company relating to those covered unlisted shares or similar interests has been extinguished through a merger (limited to the case where the company surviving the absorption-type merger, etc. is a person other than those who have a special relationship specified by Cabinet Order with the successor heir, etc. and no shares, etc. of that company surviving the absorption-type merger, etc. are delivered upon that merger), if the sum of the following amounts is less than the amount of inheritance tax under a grace period immediately before that merger takes effect: the inheritance tax equivalent to the remaining amount after deducting that sum from that amount of inheritance tax under a grace period;

イthe amount specified by Order of the Ministry of Finance as the amount equivalent to the market value of those covered unlisted shares or similar interests immediately before that merger takes effect (or, in the case where the amount specified by that Order of the Ministry of Finance is lower than the amount of the consideration for the merger (meaning the property that the company surviving the absorption-type merger, etc. delivers, upon that merger, to the shareholders or members of the certified succession company being extinguished), that amount of the consideration for the merger);

ロthe total of the amount of dividends of surplus, etc. that the successor heir, etc. and persons who share the same livelihood with the successor heir, etc. received from that certified succession company and other amounts specified by Cabinet Order as amounts received from that certified succession company, within five years on or before the day on which that merger takes effect;

四in the case where, on or after the day following the last day of the business succession period, the certified succession company relating to those covered unlisted shares or similar interests has become a wholly owned subsidiary company resulting from a share exchange or share transfer of another company through a share exchange, etc. (limited to the case where that other company is a person other than those who have a special relationship specified by Cabinet Order with the successor heir, etc. and no shares, etc. of that other company are delivered upon that share exchange, etc.), if the sum of the following amounts is less than the amount of inheritance tax under a grace period immediately before that share exchange, etc. takes effect: the inheritance tax equivalent to the remaining amount after deducting that sum from that amount of inheritance tax under a grace period.

イthe amount specified by Order of the Ministry of Finance as the amount equivalent to the market value of those covered unlisted shares or similar interests immediately before that share exchange, etc. takes effect (or, in the case where the amount specified by that Order of the Ministry of Finance is lower than the amount of the consideration for the share exchange, etc. (meaning the property that the other company delivers, upon that share exchange, etc., to the shareholders of the certified succession company that has become the wholly owned subsidiary company resulting from a share exchange or share transfer), that amount of the consideration for the share exchange, etc.);

ロthe total of the amount of dividends of surplus, etc. that the successor heir, etc. and persons who share the same livelihood with the successor heir, etc. received from that certified succession company and other amounts specified by Cabinet Order as amounts received from that certified succession company, within five years on or before the day on which that share exchange, etc. takes effect.

一that recalculated deferred inheritance tax;

二the total of the amount of dividends of surplus, etc. that the successor heir, etc. and persons who share the same livelihood with the successor heir, etc. received from that certified succession company and other amounts specified by Cabinet Order as amounts received from that certified succession company, within five years before the date of the confirmation order.

一the total value of the assets of that certified succession company;

二the total value of the assets acquired by capital contribution in kind, etc. (or, in the case where that certified succession company does not hold the assets acquired by capital contribution in kind, etc. at the time of the commencement of the succession, the value of those assets acquired by capital contribution in kind, etc. on the assumption that it held them at the time of the commencement of the succession).

一in the case specified by Cabinet Order as the case where the assets used for the business of that certified succession company have suffered severe damage due to a disaster: even if that certified succession company has come to fall under the case listed in paragraph (3), item (ii) or item (ix) within the business succession period (limited to the period on or after the day on which that disaster occurred; the same applies hereinafter in this paragraph and in paragraph (33)), or under the case listed in the left-hand column of item (i) of the table in paragraph (5) (limited to the part relating to paragraph (3), item (ix)) within the specified period (meaning the period from the day following the last day of the business succession period until the day on which 10 years have elapsed on or after the day following the base date for management reports immediately preceding the day on which that disaster occurred (or, in the case where the first base date for management reports arrives after the day on which that disaster occurred, the period from the day following that base date for management reports until the day on which 10 years have elapsed on or after that day); the same applies hereinafter through item (iv)), that certified succession company is deemed not to fall under those cases;

二in the case specified by Cabinet Order as the case where it has become difficult to secure employment at that certified succession company as a result of damage suffered due to a disaster by a business office of that certified succession company (limited to an office, store, factory or other similar facility where regular employees work; the same applies in (a)) (excluding the case falling under the case listed in the preceding item): as specified below:

イeven if that certified succession company has come to fall under the case listed in paragraph (3), item (ii) because the number calculated by dividing the sum of the numbers of regular employees of that business office (referred to as a "disaster-damaged business office" in (a)) as of each base date within the employee number confirmation period (limited to the period on or after the day on which that disaster occurred; the same applies in (a)) by the number of base dates within the employee number confirmation period, as of the last day of the employee number confirmation period, has fallen below the number specified by Cabinet Order as the number at which the employment of regular employees of that disaster-damaged business office is deemed to be secured (in the case where the business offices of that certified succession company include a business office other than a disaster-damaged business office, limited to the case where the number calculated by dividing the sum of the numbers of regular employees of that business office as of each base date within the employee number confirmation period by the number of base dates within the employee number confirmation period, as of the last day of the employee number confirmation period, is equal to or more than the number specified by Cabinet Order as the number at which the employment of regular employees of that business office is deemed to be secured), that certified succession company is deemed not to fall under the case listed in that item;

ロeven if that certified succession company has come to fall under the case listed in paragraph (3), item (ix) within the business succession period, or under the case listed in the left-hand column of item (i) of the table in paragraph (5) (limited to the part relating to paragraph (3), item (ix)) within the specified period, that certified succession company is deemed not to fall under those cases;

三in the case specified by Cabinet Order as the case where the sales amount of that certified succession company has decreased significantly due to falling under either Article 2, paragraph (5), item (i) or item (ii) of the Small and Medium-sized Enterprise Credit Insurance Act (excluding the case falling under the cases listed in the preceding two items): even if that certified succession company has come to fall under the case listed in paragraph (3), item (ii) within the business succession period, that certified succession company is deemed not to fall under the case listed in that item as of the last day of the business succession period, but only when it is a time specified by Cabinet Order as a time when the employment of regular employees commensurate with the sales amount is secured;

四in the case specified by Cabinet Order as the case where the sales amount of that certified succession company has decreased significantly due to falling under either Article 2, paragraph (5), item (iii) or item (iv) of the Small and Medium-sized Enterprise Credit Insurance Act (excluding the case falling under the cases listed in the preceding three items): even if that certified succession company has come to fall under the case listed in paragraph (3), item (ii) or item (ix) within the business succession period, or under the case listed in the left-hand column of item (i) of the table in paragraph (5) (limited to the part relating to paragraph (3), item (ix)) within the specified period, that certified succession company is deemed, only when it is a time specified by Cabinet Order as a time when the employment of regular employees commensurate with the sales amount is secured, not to fall under those cases as of the last day of the business succession period (or, in the case of having come to fall under the case listed in paragraph (3), item (ix) within the business succession period or under the case listed in the left-hand column of item (i) of that table (limited to the part relating to item (ix) of that paragraph) within the specified period, during the period from the day following the base date for management reports immediately preceding the base date for management reports (limited to one falling within the business year following the business year to which that sales amount relates; referred to as the "base date" in this item) until that base date (or, in the case listed in (a) or (b) below, the period specified in (a) or (b), respectively)).

イin the case where that base date is the first base date for management reports: the period from the day following the due date for filing the inheritance tax return for the inheritance to which the provisions of paragraph (1) apply until that base date;

ロin the case where the base date for management reports falls within the specified period: the period from the day following the immediately preceding specified base date (meaning each day on which one year elapses from the last day of the business succession period; referred to as a "specified base date" in (b)) (or, in the case where the day on which that one year elapses is the first specified base date, the last day of the business succession period) until the next specified base date (limited to one falling within the business year following the business year to which that sales amount relates (limited to a business year before the business year specified by Cabinet Order as the business year in which that sales amount first recovered to the level before falling under either Article 2, paragraph (5), item (iii) or item (iv) of the Small and Medium-sized Enterprise Credit Insurance Act)).

一when the successor heir, etc. has made a transfer, etc. of all of the unlisted shares or similar interests of that certified succession company (limited to when it falls under either (a) or (b) below, and excluding when that certified succession company has become a wholly owned subsidiary company resulting from a share exchange or share transfer of another company through a share exchange, etc. (limited to when that other company is a person other than those who have a special relationship specified by Cabinet Order with the successor heir, etc. and no shares, etc. of that other company are delivered upon that share exchange, etc.));

イwhen that transfer, etc. is made to a person specified by Cabinet Order as a single person among persons other than those who have a special relationship specified by Cabinet Order with the successor heir, etc.;

ロwhen that transfer, etc. is made, in the case where a confirmation order for a rehabilitation plan under the provisions of the Civil Rehabilitation Act or for a reorganization plan under the provisions of the Corporate Reorganization Act has been issued, in order to cancel those unlisted shares or similar interests based on that rehabilitation plan or that reorganization plan;

二when an order commencing bankruptcy proceedings or an order to commence special liquidation has been issued with regard to the certified succession company relating to those covered unlisted shares or similar interests.

一the case specified by Cabinet Order as the case where the assets used for the business of that company have suffered severe damage due to a disaster;

二the case specified by Cabinet Order as the case where it has become difficult to secure employment at that company as a result of damage suffered due to a disaster by a business office of that company (limited to an office, store, factory or other similar facility where regular employees work) (excluding the case falling under the case listed in the preceding item);

三the case specified by Cabinet Order as the case where the sales amount of that company has decreased significantly due to falling under either Article 2, paragraph (5), item (iii) or item (iv) of the Small and Medium-sized Enterprise Credit Insurance Act (excluding the case falling under the cases listed in the preceding two items).