一a resident where any of the following ratios of the resident pertaining to a foreign affiliated company is 10 percent or more:

イthe ratio of the total number or total amount of the number or amount of the shares, etc. of a foreign affiliated company held by the resident (where there is a relationship of substantive control between that foreign affiliated company and a resident or domestic corporation, zero) and the number or amount of the shares, etc. of that foreign affiliated company specified by Cabinet Order as being held indirectly through another foreign corporation, to the total number or total amount of the issued shares or capital contributions of that foreign affiliated company (excluding its own shares, etc. held by itself; referred to as "issued shares, etc." in the following paragraph and paragraphs (8) and (10));

ロthe ratio of the total number of the number of voting rights in a foreign affiliated company held by the resident (limited to voting rights pertaining to resolutions on dividends of surplus, etc.; the same applies in (b) and in item (i), (a), 2. of the following paragraph) (where there is a relationship of substantive control between that foreign affiliated company and a resident or domestic corporation, zero) and the number of voting rights in that foreign affiliated company specified by Cabinet Order as being held indirectly through another foreign corporation, to the total number of voting rights in that foreign affiliated company; or

ハthe ratio of the total amount of the amount of dividends of surplus, etc. receivable based on the claims in the shares, etc. of a foreign affiliated company held by the resident (where there is a relationship of substantive control between that foreign affiliated company and a resident or domestic corporation, zero) and the amount specified by Cabinet Order as the amount of dividends of surplus, etc. receivable based on the claims in the shares, etc. of that foreign affiliated company held indirectly through another foreign corporation, to the total amount of dividends of surplus, etc. receivable based on the claims in the shares, etc. of that foreign affiliated company.

二a resident who has a relationship of substantive control with a foreign affiliated company;

三the relevant resident (excluding a resident listed in item (i)) in the case where any of the ratios listed in item (i), (a) through (c) of a foreign affiliated company (limited to one that has a relationship of substantive control with a resident) pertaining to another foreign affiliated company is 10 percent or more; or

四a resident who belongs to a family shareholder group (meaning, among persons who directly or indirectly hold shares, etc. of a foreign affiliated company and persons who have a relationship of substantive control with a person who directly or indirectly holds those shares, etc. (excluding persons who directly or indirectly hold those shares, etc.), a single resident or domestic corporation, persons who have a relationship of substantive control with that single resident or domestic corporation, and persons who have a special relationship specified by Cabinet Order with that single resident or domestic corporation (excluding foreign corporations)) for which any of the ratios listed in item (i), (a) through (c) pertaining to a foreign affiliated company is 10 percent or more (limited to a resident for whom any of the ratios listed in (a) through (c) of that item pertaining to the foreign affiliated company, or any of the ratios listed in (a) through (c) of that item of another foreign affiliated company (limited to one that has a relationship of substantive control with a resident) pertaining to that foreign affiliated company, exceeds zero, and excluding residents listed in that item and the preceding item).

一foreign affiliated company: any of the following foreign corporations:

イa foreign corporation in the case where any of the following ratios of residents, domestic corporations, specially-related nonresidents (meaning nonresidents who have a special relationship specified by Cabinet Order with a resident or domestic corporation), and foreign corporations listed in (b) (referred to as "residents and other shareholders, etc." in (a)) pertaining to that foreign corporation exceeds 50 percent:

（１）the ratio obtained by adding together the direct shareholding ratio of residents and other shareholders, etc. pertaining to a foreign corporation (excluding a foreign corporation listed in (b)) (meaning the ratio of the number or amount of the shares, etc. of that foreign corporation held by residents and other shareholders, etc. to the total number or total amount of its issued shares, etc.) and the indirect shareholding ratio of residents and other shareholders, etc. pertaining to that foreign corporation (meaning the ratio specified by Cabinet Order as the ratio of the number or amount of the shares, etc. of that foreign corporation held indirectly by residents and other shareholders, etc. through another foreign corporation to the total number or total amount of its issued shares, etc.);

（２）the ratio obtained by adding together the direct voting rights holding ratio of residents and other shareholders, etc. pertaining to a foreign corporation (excluding a foreign corporation listed in (b)) (meaning the ratio of the number of voting rights in that foreign corporation held by residents and other shareholders, etc. to the total number of those voting rights) and the indirect voting rights holding ratio of residents and other shareholders, etc. pertaining to that foreign corporation (meaning the ratio specified by Cabinet Order as the ratio of the number of voting rights in that foreign corporation held indirectly by residents and other shareholders, etc. through another foreign corporation to the total number of those voting rights); or

（３）the ratio obtained by adding together the direct claim holding ratio of residents and other shareholders, etc. pertaining to a foreign corporation (excluding a foreign corporation listed in (b)) (meaning the ratio of the amount of dividends of surplus, etc. receivable based on the claims in the shares, etc. of that foreign corporation held by residents and other shareholders, etc. to the total amount thereof) and the indirect claim holding ratio of residents and other shareholders, etc. pertaining to that foreign corporation (meaning the ratio specified by Cabinet Order as the ratio of the amount of dividends of surplus, etc. receivable based on the claims in the shares, etc. of that foreign corporation held indirectly by residents and other shareholders, etc. through another foreign corporation to the total amount thereof);

ロa foreign corporation that has a relationship of substantive control with a resident or domestic corporation; or

ハa foreign corporation that would fall under the category of foreign financial institution prescribed in item (vii) if the provisions of item (vi) and item (vii) were applied by deeming the phrase "foreign affiliated company (excluding one that falls under the category of specified foreign affiliated company)" in item (vi) to be "foreign corporation", which is specified by Cabinet Order as a foreign corporation that has, with a partially covered foreign affiliated company specified by Cabinet Order as being equivalent to a foreign financial institution prescribed in that item, a relationship in which that partially covered foreign affiliated company performs the business management of that foreign corporation, or any other special relationship.

二specified foreign affiliated company: any of the following foreign affiliated companies:

イa foreign affiliated company that falls under none of the following:

（１）a foreign affiliated company that has an office, store, factory or any other fixed facility that is found to be necessary for conducting its principal business;

（２）a foreign affiliated company that manages, controls and operates its business by itself in the state or territory where its head office or principal office is located (referred to as the "state of the head office" in this paragraph and paragraphs (8) and (10));

（３）a foreign affiliated company whose principal business is the holding of shares, etc. of a foreign subsidiary (meaning a foreign corporation whose state of the head office is the same as that of that foreign affiliated company and that satisfies the requirements specified by Cabinet Order, such as the ratio of the number or amount of the shares, etc. of that foreign corporation held by that foreign affiliated company to the total number or total amount of its issued shares, etc. being 25 percent or more), and that satisfies the requirements specified by Cabinet Order, such as the ratio of the amount of dividends of surplus, etc. pertaining to those shares, etc. to its revenue being significantly high;

（４）a foreign affiliated company whose principal business is the holding of shares, etc. of a specified subsidiary (meaning another foreign affiliated company pertaining to a resident listed in any of the items of the preceding paragraph that falls under the category of partially covered foreign affiliated company or that is otherwise specified by Cabinet Order), and that satisfies the requirements specified by Cabinet Order, such as its business being managed, controlled and operated by a management and control company with the same state of the head office (meaning, among the other foreign affiliated companies pertaining to that resident, one that falls under the category of partially covered foreign affiliated company and whose officers (meaning officers prescribed in Article 2, item (xv) of the Corporation Tax Act; the same applies in the following item, item (vii) and paragraph (8)) or employees engage, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out its principal business; the same applies in 4. and 5.), that management and control company performing functions indispensable for carrying out the business it conducts in its state of the head office, and the ratio of the amount of dividends of surplus, etc. pertaining to those shares, etc. and the amount of consideration for the transfer of those shares, etc. to its revenue being significantly high; or

（５）a foreign affiliated company that performs functions indispensable for carrying out a business concerning the holding of real property located in its state of the head office, the exploration, development or extraction of petroleum or other natural resources in its state of the head office, or the development of social infrastructure in its state of the head office, and that satisfies the requirements specified by Cabinet Order, such as its business being managed, controlled and operated by a management and control company with the same state of the head office;

ロa foreign affiliated company for which the ratio of the total of the amounts equivalent to the amounts listed in paragraph (8), items (i) through (vii) and items (viii) through (x) to the amount specified by Cabinet Order as the amount of its total assets (referred to as the "amount of total assets" in (b)) (in the case of a foreign affiliated company that would fall under the category of foreign financial subsidiary, etc. if the provisions of item (vi) and item (vii) were applied by deeming the phrase "foreign affiliated company (excluding one that falls under the category of specified foreign affiliated company)" in item (vi) to be "foreign affiliated company", the ratio to the amount of total assets of the amount equivalent to the amount listed in paragraph (10), item (i) or the total of the amounts equivalent to the amounts listed in items (ii) through (iv) of that paragraph, whichever is greater) exceeds 30 percent (limited to a foreign affiliated company for which the ratio to the amount of total assets of the amount specified by Cabinet Order as the total amount of Securities (meaning Securities prescribed in Article 2, item (xxi) of the Corporation Tax Act; the same applies in paragraph (8)), loans and other assets specified by Cabinet Order exceeds 50 percent);

ハa foreign affiliated company that satisfies both of the following requirements:

（１）the ratio calculated pursuant to the provisions of Cabinet Order as the ratio of the total amount of premium income from non-affiliates, etc. for each business year (meaning premium income specified by Cabinet Order as that received from persons other than related parties (meaning a resident listed in any of the items of the preceding paragraph pertaining to that foreign affiliated company, a domestic corporation listed in any of the items of Article 66-6, paragraph (1), and any other person specified by Cabinet Order as being equivalent to those persons; the same applies in 2.); the same applies in 2.) to the total amount of premium income is less than 10 percent;

（２）the ratio calculated pursuant to the provisions of Cabinet Order as the ratio of the total amount of reinsurance premiums paid to non-affiliates, etc. for each business year (meaning the amount specified by Cabinet Order as the amount obtained by apportioning the total amount of reinsurance premiums paid to persons other than related parties by the ratio of the total amount of premium income from related parties, etc. (meaning premium income other than premium income from non-affiliates, etc.; the same applies in 2.) to the total amount of premium income) to the total amount of premium income from related parties, etc. is less than 50 percent; or

ニa foreign affiliated company that has its head office or principal office in a state or territory designated by the Minister of Finance as a state or territory whose cooperation with international efforts concerning the exchange of information on taxation is significantly insufficient.

三covered foreign affiliated company: a foreign affiliated company (excluding one that falls under the category of specified foreign affiliated company) that fails to satisfy one or more of the following requirements:

イit is not a company whose principal business is the holding of shares, etc. or bonds, the provision of industrial property rights or any other rights concerning technology, production methods involving special technology or anything equivalent thereto (including the right to use these rights) or copyrights (including rights of publication, neighboring rights and any other equivalent rights), or the lending of vessels or aircraft (excluding the following):

（１）among foreign affiliated companies whose principal business is the holding of shares, etc., one specified by Cabinet Order as holding the shares, etc. of the other corporations specified by Cabinet Order in the case where that foreign affiliated company conducts operations specified by Cabinet Order as operations that contribute to improving the profitability of other corporations through the comprehensive management and coordination of their business activities (referred to as "supervisory business" in (b));

（２）among foreign affiliated companies whose principal business is the holding of shares, etc., one that would fall under the category of foreign financial subsidiary, etc. if the provisions of item (vii) were applied by deeming the phrase "partially covered foreign affiliated company" in that item to be "foreign affiliated company" (excluding one that would fall under the category of foreign financial institution prescribed in that item and one listed in 1.); or

（３）among foreign affiliated companies whose principal business is the lending of aircraft, one that satisfies the requirements specified by Cabinet Order, such as its officers or employees engaging, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out the lending of aircraft.

ロit satisfies both of the following: it has, in its state of the head office, an office, store, factory or any other fixed facility that is found to be necessary for conducting its principal business (in the case of a foreign affiliated company listed in (a), 1., supervisory business, and in the case of a foreign affiliated company listed in (a), 2., the business management specified by Cabinet Order; the same applies in (c)); and it manages, controls and operates its business by itself in its state of the head office;

ハit falls under the case specified in the following according to which of the following businesses the principal business it conducts in each business year falls under:

（１）wholesale business, banking business, trust business, financial instruments business, insurance business, water transportation business, air transportation business or goods leasing business (limited to one whose principal business is the lending of aircraft): The case specified by Cabinet Order in which the foreign affiliated company conducts business mainly with a person other than [1] a resident listed in each item of the preceding paragraph pertaining to the foreign affiliated company, [2] a domestic corporation listed in each item of Article 66-6, paragraph (1) or [3] any other person specified by Cabinet Order as being equivalent to the persons mentioned in [1] and [2]; or

（２）business other than that listed in 1.: The case specified by Cabinet Order in which the foreign affiliated company conducts the business mainly in its state of the head office (including the water areas belonging to the state of the head office which are specified by Cabinet Order).

四amount of applicable income: An amount adjusted, with respect to the amount of income of a specified foreign affiliated company or covered foreign affiliated company in its settlement of accounts for each business year, pursuant to the method specified by Cabinet Order, based on the amount calculated in accordance with the standards specified by Cabinet Order in a manner equivalent to the manner for calculating the amount of income for each business year pursuant to the Corporation Tax Act and this Act (referred to as the "base income amount" in this item), in terms of the amount of loss incurred in each of the business years that commenced within seven years before the first day of the relevant business year and the tax amount pertaining to that base income amount;

五relationship of substantive control: the relationship between a resident or domestic corporation and a foreign corporation in the case where that resident or domestic corporation has the right to claim substantially all of the residual assets of that foreign corporation, or any other relationship specified by Cabinet Order;

六partially covered foreign affiliated company: a foreign affiliated company (excluding one that falls under the category of specified foreign affiliated company) that satisfies all of the requirements listed in item (iii), (a) through (c);

七foreign financial subsidiary, etc.: a partially covered foreign affiliated company that engages in the banking business, financial instruments business (limited to operations of the same type as Type I Financial Instruments Business prescribed in Article 28, paragraph (1) of the Financial Instruments and Exchange Act) or insurance business in accordance with the laws and regulations of its state of the head office and whose officers or employees engage, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out those businesses (referred to as a "foreign financial institution" in this item), and a partially covered foreign affiliated company specified by Cabinet Order as being equivalent to a foreign financial institution;

八liquidating partially covered foreign affiliated company: among dissolved foreign affiliated companies, one that fell under the category of partially covered foreign affiliated company in each of the business years that commenced within two years before the first day of the business year that includes the date of its dissolution;

九liquidating foreign financial subsidiary, etc.: among dissolved foreign affiliated companies, one that fell under the category of foreign financial subsidiary, etc. in each of the business years that commenced within one year before the first day of the business year that includes the date of its dissolution;

十special liquidation business year: a business year that includes any day within the period from the last day of the business year in which a liquidating partially covered foreign affiliated company or liquidating foreign financial subsidiary, etc. first ceased to fall under the category of partially covered foreign affiliated company or foreign financial subsidiary, etc. until the day on which three years have elapsed after that day (where the date of determination of the residual assets of that liquidating partially covered foreign affiliated company or liquidating foreign financial subsidiary, etc. is before the day on which those three years have elapsed, the date of determination of those residual assets, and where, due to the laws and regulations or practices of its state of the head office or other unavoidable reasons, the date of determination of those residual assets is after the day on which those three years have elapsed, the day specified by Cabinet Order).

一specified foreign affiliated company: where the tax burden ratio of the specified foreign affiliated company for each business year (meaning the ratio calculated pursuant to the provisions of Cabinet Order as the ratio of the amount of taxes imposed on the income of a foreign affiliated company for each business year to the amount of that income; the same applies in the following item and paragraphs (12) and (14)) is 27 percent or more; or

二covered foreign affiliated company: where the tax burden ratio of the covered foreign affiliated company for each business year is 20 percent or more.

一the remaining amount obtained by deducting, from the total amount of dividends of surplus, etc. (meaning dividends of surplus, etc. prescribed in paragraph (1), including distributions of monies prescribed in Article 23, paragraph (1), item (ii) of the Corporation Tax Act; the same applies hereinafter in this item and in item (xi), (a)) (excluding the amount of dividends of surplus, etc. received from another corporation in the case where the requirements specified by Cabinet Order are satisfied, such as the ratio of the number or amount of the shares, etc. of that other corporation held by that partially covered foreign affiliated company to the total number or total amount of its issued shares, etc. being 25 percent or more (excluding the amount of dividends of surplus, etc. specified by Cabinet Order as dividends of surplus, etc. that are to be included in deductible expenses in calculating the amount of income of that other corporation); the same applies hereinafter in this item), the total amount of expenses directly incurred to obtain those dividends of surplus, etc. and the amount calculated pursuant to the provisions of Cabinet Order as the amount of expenses pertaining to those dividends of surplus, etc.;

二the remaining amount obtained by deducting, from the total amount of interest received, etc. (meaning interest that it receives (including anything specified by Cabinet Order as equivalent thereto; the same applies hereinafter in this item); the same applies hereinafter in this item and in item (xi), (b)) (excluding the amount of interest on deposits or savings (including those equivalent to those specified by Cabinet Order prescribed in Article 2, paragraph (1), item (x) of the Income Tax Act) arising in the ordinary course of operations pertaining to the business it conducts, the amount of interest pertaining to the lending of money conducted by a partially covered foreign affiliated company whose principal business is the lending of money (limited to one that has received a license, registration or any other similar disposition in its state of the head office under the provisions of the laws and regulations of its state of the head office with regard to engaging in the lending of money as a business) and whose officers or employees engage, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out the money lending business it conducts, and the amount of other interest specified by Cabinet Order; the same applies hereinafter in this item), the total amount of expenses directly incurred to obtain that interest received, etc.;

三the remaining amount obtained by deducting, from the total amount of consideration for the lending of Securities, the total amount of expenses directly incurred to obtain that consideration;

四the amount obtained by subtracting, from the total amount of consideration for the transfer of Securities (excluding the amount of consideration for the transfer of shares, etc. of another corporation in the case where the ratio of the number or amount of the shares, etc. of that other corporation held by that partially covered foreign affiliated company to the total number or total amount of its issued shares, etc. is 25 percent or more immediately before that transfer; the same applies hereinafter in this item), the total amount calculated pursuant to the provisions of Cabinet Order as the cost of those Securities transferred and the total amount of expenses directly incurred to obtain that consideration;

五the amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or loss pertaining to derivative transactions (meaning derivative transactions prescribed in Article 61-5, paragraph (1) of the Corporation Tax Act; the same applies hereinafter in this item and in item (xi), (e)) (excluding the amount of profit or loss pertaining to derivative transactions specified by Order of the Ministry of Finance as derivative transactions conducted to reduce the losses listed in the items of Article 61-6, paragraph (1) of that Act, the amount of profit or loss pertaining to derivative transactions specified by Order of the Ministry of Finance conducted by a partially covered foreign affiliated company that, in accordance with the laws and regulations of its state of the head office, engages as a business in acts equivalent to the acts listed in the items of Article 2, paragraph (22) of the Commodity Derivatives Transaction Act (Act No. 239 of 1950) (limited to one whose officers or employees engage, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out the business pertaining to those acts it conducts), and the amount of profit or loss pertaining to other derivative transactions specified by Order of the Ministry of Finance);

六the amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or loss arising from fluctuations in foreign exchange rates with respect to transactions it conducts or assets or liabilities it holds (excluding the amount of profit or loss arising in the ordinary course of operations pertaining to the business it conducts (excluding a business that conducts transactions specified by Cabinet Order));

七the amount of profit or loss arising from the investment, holding, transfer, lending or other acts with respect to assets that give rise to the profit or loss pertaining to the amounts listed in the preceding items (including similar profit or loss) (excluding the profit or loss pertaining to the amounts listed in those items and the amount of profit or loss pertaining to transactions specified by Order of the Ministry of Finance as transactions conducted to reduce the losses listed in the items of Article 61-6, paragraph (1) of the Corporation Tax Act);

七の二the amount obtained by subtracting the amount listed in (b) from the amount listed in (a):

イthe amount specified by Cabinet Order as equivalent to the remaining amount obtained by deducting the total amount of reinsurance premiums paid from the total amount of premium income;

ロthe amount specified by Cabinet Order as equivalent to the remaining amount obtained by deducting the total amount of reinsurance proceeds received from the total amount of insurance claims paid;

八the remaining amount obtained by deducting, from the total amount of consideration for the lending of fixed assets (meaning fixed assets prescribed in Article 2, item (xxii) of the Corporation Tax Act, excluding those specified by Cabinet Order; the same applies hereinafter in this item and in item (xi), (i)) (including acts of having another person use real property or rights existing on real property) (excluding the amount of consideration for the lending of fixed assets (excluding real property and rights existing on real property) that are mainly used in its state of the head office, the amount of consideration for the lending of real property or rights existing on real property located in its state of the head office (including acts of having another person use them), and the amount of consideration for the lending of fixed assets conducted by a partially covered foreign affiliated company that satisfies the requirements specified by Cabinet Order, such as its officers or employees engaging, in its state of the head office, in all of the operations normally found to be necessary for properly carrying out the lending of fixed assets (including acts of having another person use real property or rights existing on real property; the same applies hereinafter in this item and in item (xi), (i)); the same applies hereinafter in this item), the total amount of expenses directly incurred to obtain that consideration (including the amount calculated pursuant to the provisions of Cabinet Order as the amount of depreciation allowance for the fixed assets it holds);

九the remaining amount obtained by deducting, from the total amount of royalties for industrial property rights or any other rights concerning technology, production methods involving special technology or anything equivalent thereto (including the right to use these rights) or copyrights (including rights of publication, neighboring rights and any other equivalent rights) (referred to as "intangible assets, etc." in this paragraph) (excluding royalties for intangible assets, etc. resulting from research and development it has conducted itself and other royalties specified by Cabinet Order; the same applies hereinafter in this item), the total amount of expenses directly incurred to obtain those royalties (including the amount calculated pursuant to the provisions of Cabinet Order as the amount of depreciation allowance for the intangible assets, etc. it holds);

十the amount obtained by subtracting, from the total amount of consideration for the transfer of intangible assets, etc. (excluding the amount of consideration for the transfer of intangible assets, etc. resulting from research and development it has conducted itself and other amounts of consideration specified by Cabinet Order; the same applies hereinafter in this item), the total cost of the intangible assets, etc. transferred and the total amount of expenses directly incurred to obtain that consideration;

十一the remaining amount obtained by deducting the amount listed in (l) pertaining to each business year from the amount specified by Cabinet Order as the amount of income of that partially covered foreign affiliated company for that business year, calculated as if there were none of the amounts listed in (a) through (k):

イthe amount of dividends of surplus, etc. received;

ロthe amount of interest received, etc.;

ハthe amount of consideration for the lending of Securities;

ニthe amount obtained by subtracting, from the total amount of consideration for the transfer of Securities, the total amount calculated pursuant to the provisions of Cabinet Order as the cost of those Securities transferred;

ホthe amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or loss pertaining to derivative transactions;

ヘthe amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or loss arising from fluctuations in foreign exchange rates with respect to transactions it conducts or assets or liabilities it holds;

トthe amount of profit or the amount of loss arising from the investment, holding, transfer, or lending of, or any other act involving, assets that give rise to the amount of profit or the amount of loss pertaining to the amounts listed in items (i) through (vi) (including any amount of profit or amount of loss similar thereto) (excluding the amount of profit or the amount of loss pertaining to the amounts listed in those items);

チthe amount listed in item (vii)-2;

リthe amount of consideration for the lending of fixed assets;

ヌroyalties received for intangible assets, etc.;

ルthe amount obtained by subtracting, from the total amount of consideration for the transfer of intangible assets, etc., the total amount of costs of the transfer of those intangible assets, etc.;

ヲthe amount calculated by multiplying the amount obtained by adding the amount of personnel expenses and other expenses specified by Cabinet Order to the amount specified by Cabinet Order as the amount of total assets, by 50 percent.

一the amount calculated pursuant to the method specified by Cabinet Order as the amount of profit pertaining to the capital equivalent to the excess, in the case where the amount equivalent to the parent company's equity, etc. of a partially covered foreign affiliated company whose issued shares, etc. are all held directly or indirectly by a single resident and which satisfies the requirements specified by Cabinet Order (limited to one for which the ratio of the amount specified by Cabinet Order as the amount obtained by making adjustments to its net assets with regard to surplus and other matters (hereinafter referred to in this item as the "amount equivalent to the parent company's equity, etc.") to the amount specified by Cabinet Order as the amount of its total assets exceeds 70 percent) exceeds the amount specified by Cabinet Order by taking into consideration the amount of capital below which it may not fall under the laws and regulations of its state of the head office;

二the amount equivalent to the amount listed in paragraph (8), item (viii) that is obtained when the amount is calculated for the partially covered foreign affiliated company in accordance with the provisions of that item;

三the amount equivalent to the amount listed in paragraph (8), item (ix) that is obtained when the amount is calculated for the partially covered foreign affiliated company in accordance with the provisions of that item;

四the amount equivalent to the amount listed in paragraph (8), item (x) that is obtained when the amount is calculated for the partially covered foreign affiliated company in accordance with the provisions of that item;

五the amount equivalent to the amount listed in paragraph (8), item (xi) that is obtained when the amount is calculated for the partially covered foreign affiliated company in accordance with the provisions of that item.

一the amount listed in item (i) of the preceding paragraph;

二the sum of the total of the amounts listed in item (ii), item (iii) and item (v) of the preceding paragraph, and the amount obtained by making adjustments pursuant to the method specified by Cabinet Order, based on the amount listed in item (iv) of that paragraph (if that amount is less than zero, zero), with regard to the amount of the portion by which the amount listed in that item arising in each business year that began within seven years before the first day of the relevant business year fell below zero.

一the tax burden ratio for each business year is 20 percent or more;

二the partially applicable amount or the partially applicable amount for a financial subsidiary, etc. in each business year is 20 million yen or less;

三the ratio of the partially applicable amount or the partially applicable amount for a financial subsidiary, etc. in each business year to the amount specified by Cabinet Order as the amount equivalent to the amount of income based on the settlement of accounts for the relevant business year is 5 percent or less.

一a partially covered foreign affiliated company whose tax burden ratio for each business year concerned is less than 20 percent (excluding any partially covered foreign affiliated company to which either of the facts referred to in paragraph (12), item (ii) or item (iii) applies in the relevant business year (referred to in the following paragraph as a "partially covered foreign affiliated company exempt from attachment"));

二a covered foreign affiliated company whose tax burden ratio for each business year concerned is less than 20 percent;

三a specified foreign affiliated company whose tax burden ratio for each business year concerned is less than 27 percent.

一the amount calculated pursuant to the method specified by Cabinet Order, by taking into consideration the number of shares, etc. held directly by the resident in the foreign corporation (meaning the number of shares of or amount of capital contributions to a foreign corporation held by a resident; the same applies in the following item and item (i) of the following paragraph) and the status of the relationship of substantive control between the resident and the foreign corporation (meaning the relationship of substantive control prescribed in paragraph (2), item (v) of that Article; the same applies in the following item and item (ii) of the following paragraph), out of the taxable amount, partially taxable amount or partially taxable amount for a financial subsidiary, etc. pertaining to the foreign corporation that is included in gross revenue in the calculation of the amount of miscellaneous income for the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article;

二the amount calculated pursuant to the method specified by Cabinet Order, by taking into consideration the number of shares, etc. held directly by the resident in the foreign corporation and the status of the relationship of substantive control between the resident and the foreign corporation, out of the taxable amount, partially taxable amount or partially taxable amount for a financial subsidiary, etc. pertaining to the foreign corporation that was included in gross revenue in the calculation of the amount of miscellaneous income for each year within the three years preceding the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article (if there is an amount of dividends of surplus and similar distributions received from the foreign corporation in those years (limited to the portion of the amount to which the provisions of this paragraph were applied; hereinafter the same applies in this item), the balance remaining after deducting the amount equivalent to that amount of dividends of surplus and similar distributions; referred to in paragraph (3) as the "already-taxed amount").

一the amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held directly by the resident in the foreign corporation referred to in the preceding paragraph, out of the amount of dividends of surplus and similar distributions received by the foreign corporation referred to in the preceding paragraph from another foreign corporation in the year that includes the dividend date and in each year within the two years preceding that year (excluding those specified by Cabinet Order as the amount of dividends of surplus and similar distributions received before the first day of the business year of the other foreign corporation to which the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article apply) (if there is an amount of dividends of surplus and similar distributions received from the foreign corporation in each year within the two years preceding the year that includes the dividend date (referred to in (b) of the following item as "each year within the preceding two years") (limited to the portion, out of the amount to which the provisions of this paragraph were applied, corresponding to the amount of dividends of surplus and similar distributions received by the foreign corporation from the other foreign corporation; hereinafter referred to in this paragraph as the "amount of dividends, etc. to which the special rule applied"), the balance remaining after deducting the amount of dividends, etc. to which the special rule applied; referred to in the following paragraph as "indirect dividends, etc.");

二the sum of the following amounts:

イthe amount calculated pursuant to the method specified by Cabinet Order, by taking into consideration the number of shares, etc. held indirectly by the resident referred to in that item in the other foreign corporation (meaning the number of shares of or amount of capital contributions to another foreign corporation specified by Cabinet Order as being held indirectly by a resident through a foreign corporation; the same applies in (b)) and the status of the relationship of substantive control between the resident and the other foreign corporation, out of the taxable amount, partially taxable amount or partially taxable amount for a financial subsidiary, etc. pertaining to the other foreign corporation referred to in the preceding item that is included in gross revenue in the calculation of the amount of miscellaneous income for the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article;

ロthe amount calculated pursuant to the method specified by Cabinet Order, by taking into consideration the number of shares, etc. held indirectly by the resident referred to in that item in the other foreign corporation and the status of the relationship of substantive control between the resident and the other foreign corporation, out of the taxable amount, partially taxable amount or partially taxable amount for a financial subsidiary, etc. pertaining to the other foreign corporation referred to in the preceding item that was included in gross revenue in the calculation of the amount of miscellaneous income for each year within the preceding two years pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article (if there is an amount of dividends, etc. to which the special rule applied that was received from the foreign corporation referred to in the preceding paragraph in each year within the preceding two years, the balance remaining after deducting that amount of dividends, etc. to which the special rule applied; referred to in the following paragraph as the "indirectly taxed amount").

一specified shareholder, etc.: An individual and corporation holding, at the time immediately before a specified relationship is established, shares, etc. of a specified domestic corporation (meaning a domestic corporation wherein five or fewer shareholders, etc. (meaning shareholders, etc. prescribed in Article 2, paragraph (1), item (viii)-2 of the Income Tax Act) as well as individuals and corporations that have a special relationship thereto as specified by Cabinet Order hold shares, etc. that account for 80 percent or more of the total number or total amount of its issued shares, etc. at that time; the same applies in the following item);

二specially-related domestic corporation: A specified domestic corporation, or a domestic corporation specified by Cabinet Order as a corporation that has received the transfer of the majority of assets and liabilities from a specified domestic corporation;

三specified foreign affiliated corporation: Any of the following foreign affiliated corporations:

イa foreign affiliated corporation that falls under none of the following:

（１）a foreign affiliated corporation that has an office, store, factory or other fixed facilities found to be necessary for conducting its principal business;

（２）a foreign affiliated corporation that itself conducts the management, control and operation of its business in the state or territory where its head office or principal office is located (hereinafter referred to in this paragraph, paragraph (8) and paragraph (10) as the "state of the head office");

（３）a foreign affiliated corporation whose principal business is the holding of shares, etc. of a foreign subsidiary corporation (meaning a foreign corporation whose state of the head office is the same as that of the foreign affiliated corporation and which satisfies the requirements specified by Cabinet Order, such as the requirement that the ratio of the number or amount of shares, etc. of the foreign corporation held by the foreign affiliated corporation to the total number or total amount of its issued shares, etc. is 25 percent or more), and which satisfies the requirements specified by Cabinet Order, such as the requirement that the ratio of the amount of dividends of surplus and similar distributions pertaining to those shares, etc. to its revenue is extremely high;

（４）a foreign affiliated corporation whose principal business is the holding of shares, etc. of a specified subsidiary corporation (meaning another foreign affiliated corporation pertaining to the resident who is a specially-related shareholder, etc. that falls under the category of a partially covered foreign affiliated corporation, or any other corporation specified by Cabinet Order), and which satisfies the requirements specified by Cabinet Order, such as the requirements that the management, control and operation of its business are conducted by a management and control corporation whose state of the head office is the same as its own (meaning, among other foreign affiliated corporations pertaining to the resident, one that falls under the category of a partially covered foreign affiliated corporation and whose officers (meaning officers prescribed in Article 2, item (xv) of the Corporation Tax Act; the same applies in item (viii) and paragraph (8)) or employees engage, in its state of the head office, in all of the operations that are found to be ordinarily necessary to properly carry out its principal business; the same applies in 4. and 5.), that the management and control corporation performs functions indispensable for carrying out the business it conducts in its state of the head office, and that the ratio of the amount of dividends of surplus and similar distributions pertaining to those shares, etc. and the amount of consideration for the transfer of those shares, etc. to its revenue is extremely high;

（５）a foreign affiliated corporation that performs functions indispensable for carrying out a business relating to the holding of real property located in its state of the head office, the exploration, development or extraction of oil or other natural resources in its state of the head office, or the development of social infrastructure in its state of the head office, and which satisfies the requirements specified by Cabinet Order, such as the requirement that the management, control and operation of its business are conducted by a management and control corporation whose state of the head office is the same as its own.

ロa foreign affiliated corporation for which the ratio of the sum of the amounts equivalent to the amounts listed in paragraph (8), items (i) through (vii) and items (viii) through (x) to the amount specified by Cabinet Order as the amount of its total assets (referred to in (b) as the "amount of total assets") (for a foreign affiliated corporation that would fall under the category of a foreign finance-related corporation if the provisions of item (vii) and item (viii) were applied by deeming the phrase "foreign affiliated corporation (excluding one that falls under the category of a specified foreign affiliated corporation)" in item (vii) to be replaced with "foreign affiliated corporation", the ratio of the amount equivalent to the amount listed in paragraph (10), item (i) or the sum of the amounts equivalent to the amounts listed in items (ii) through (iv) of that paragraph, whichever is greater, to the amount of total assets) exceeds 30 percent (limited to a foreign affiliated corporation for which the ratio of the amount specified by Cabinet Order as the sum of the amounts of Securities (meaning Securities prescribed in Article 2, item (xxi) of the Corporation Tax Act; the same applies in paragraph (8)), loans and other assets specified by Cabinet Order to the amount of total assets exceeds 50 percent);

ハa foreign affiliated corporation that satisfies all of the following requirements:

（１）the ratio calculated pursuant to the method specified by Cabinet Order as the ratio of the total amount of premium income from non-affiliates, etc. for each business year (meaning premium income specified by Cabinet Order as being received from persons other than related parties (meaning a specially-related domestic corporation or a specially-related shareholder, etc. pertaining to the foreign affiliated corporation, or any other person specified by Cabinet Order as being equivalent thereto; the same applies in 2.); the same applies in 2.) to the total amount of premium income is less than 10 percent;

（２）the ratio calculated pursuant to the method specified by Cabinet Order as the ratio of the total amount of reinsurance premiums paid to non-affiliates, etc. for each business year (meaning the amount specified by Cabinet Order as the amount obtained by apportioning the total amount of reinsurance premiums paid to persons other than related parties according to the ratio of the total amount of premium income from related parties, etc. (meaning premium income other than premium income from non-affiliates, etc.; the same applies in 2.) to the total amount of premium income) to the total amount of premium income from related parties, etc. is less than 50 percent.

ニa foreign affiliated corporation that has its head office or principal office in a state or territory designated by the Minister of Finance as a state or territory whose cooperation with international efforts for the exchange of information on taxes is significantly insufficient.

四covered affiliated foreign corporation: A foreign affiliated corporation that does not satisfy one or more of the following requirements (excluding one that falls under the category of a specified foreign affiliated corporation):

イit is not one whose principal business is the holding of shares, etc. or bonds, the provision of industrial property rights or other rights relating to technology, production methods involving special technology or anything equivalent thereto (including rights to use those rights) or copyrights (including rights of publication, neighboring rights and anything equivalent thereto), or the leasing of ships or aircraft (excluding, among foreign affiliated corporations whose principal business is the holding of shares, etc., one that would fall under the category of a foreign finance-related corporation if the provisions of item (viii) were applied by deeming the phrase "partially covered foreign affiliated corporation" in that item to be replaced with "foreign affiliated corporation" (excluding one that would fall under the category of a foreign financial institution prescribed in that item; referred to in (b) as a "specified foreign financial holding company"));

ロit both has, in its state of the head office, an office, store, factory or other fixed facilities found to be necessary for conducting its principal business (for a specified foreign financial holding company, the business management specified by Cabinet Order; the same applies in (c)), and itself conducts the management, control and operation of its business in its state of the head office;

ハin each business year, it falls under the case specified in each of the following according to which of the following businesses its principal business falls under:

（１）wholesale business, banking business, trust business, financial instruments business, insurance business, water transportation business or air transportation business: The case specified by Cabinet Order in which the foreign affiliated corporation conducts business mainly with a person other than [1] a specially-related domestic corporation of the foreign affiliated corporation, [2] a specially-related shareholder, etc. or [3] any other person specified by Cabinet Order as being equivalent to the persons mentioned in [1] or [2]; or

（２）business other than the businesses listed in 1.: The case specified by Cabinet Order in which the foreign affiliated corporation conducts business mainly in its state of the head office (including the waters pertaining to that state of the head office that are specified by Cabinet Order as prescribed in Article 40-4, paragraph (2), item (iii), (c), 2.).

五amount of applicable income: An amount adjusted, with respect to the amount of income of a specified foreign affiliated corporation or covered affiliated foreign corporation in its settlement of accounts for each business year, pursuant to the method specified by Cabinet Order, based on the amount calculated in accordance with the standards specified by Cabinet Order in a manner equivalent to the manner for calculating the amount of income for each business year pursuant to the Corporation Tax Act and this Act (hereinafter referred to in this item as the "base income amount"), in terms of the amount of loss incurred in each of the business years that commenced within seven years before the first day of the relevant business year and the amount of tax pertaining to the base income amount;

六number of shares, etc. held through direct and/or indirect ownership: The sum of the number or amount of shares, etc. of a foreign corporation held directly by a resident or domestic corporation and the number or amount of shares, etc. of the foreign corporation specified by Cabinet Order as being held indirectly by the resident or domestic corporation via another foreign corporation;

七partially covered foreign affiliated corporation: A foreign affiliated corporation that satisfies all of the requirements listed in item (iv), (a) through (c) (excluding one that falls under the category of a specified foreign affiliated corporation);

八foreign finance-related corporation: A partially covered foreign affiliated corporation that engages in the banking business, financial instruments business (limited to business of the same type as the type I financial instruments business prescribed in Article 28, paragraph (1) of the Financial Instruments and Exchange Act) or insurance business in accordance with the laws and regulations of its state of the head office and whose officers or employees engage, in its state of the head office, in all of the operations that are found to be ordinarily necessary to properly carry out those businesses (hereinafter referred to in this item as a "foreign financial institution"), and a partially covered foreign affiliated corporation specified by Cabinet Order as being equivalent to a foreign financial institution;

九liquidating partially covered foreign affiliated corporation: A foreign affiliated corporation that has dissolved and that fell under the category of a partially covered foreign affiliated corporation in each of the business years that began within two years before the first day of the business year that includes the date of its dissolution;

十liquidating foreign financial affiliated corporation: A foreign affiliated corporation that has dissolved and that fell under the category of a foreign finance-related corporation in each of the business years that began within one year before the first day of the business year that includes the date of its dissolution;

十一special liquidation business year: A business year that includes any day within the period from the end of the business year in which a liquidating partially covered foreign affiliated corporation or liquidating foreign financial affiliated corporation first ceased to fall under the category of a partially covered foreign affiliated corporation or foreign finance-related corporation to the day on which three years have elapsed from that day (if the date of determination of the residual assets of the liquidating partially covered foreign affiliated corporation or liquidating foreign financial affiliated corporation is before the day on which those three years have elapsed, the date of determination of the residual assets, and if the date of determination of the residual assets is after the day on which those three years have elapsed due to the laws and regulations or practices of its state of the head office or for any other unavoidable reason, the day specified by Cabinet Order).

一specified foreign affiliated corporation: The case where the tax burden ratio of the specified foreign affiliated corporation for each business year (meaning the ratio calculated pursuant to the method specified by Cabinet Order as the ratio of the amount of taxes imposed on the income of a foreign affiliated corporation for each business year to the amount of that income; the same applies in the following item, paragraph (12) and paragraph (14)) is 27 percent or more;

二covered affiliated foreign corporation: The case where the tax burden ratio of the covered affiliated foreign corporation for each business year is 20 percent or more.

一the amount remaining after deducting, from the total amount of dividends of surplus and similar distributions (meaning dividends of surplus and similar distributions prescribed in paragraph (1), including distributions of monies prescribed in Article 23, paragraph (1), item (ii) of the Corporation Tax Act; hereinafter the same applies in this item and item (xi), (a)) (excluding the amount of dividends of surplus and similar distributions received from another corporation in the case where the requirements specified by Cabinet Order are satisfied, such as the requirement that the ratio of the number or amount of shares, etc. of the other corporation held by the partially covered foreign affiliated corporation to the total number or total amount of its issued shares, etc. is 25 percent or more (excluding the amount of dividends of surplus and similar distributions specified by Cabinet Order as the amount of dividends of surplus and similar distributions that is to be included in deductible expenses in the calculation of the amount of income of the other corporation); hereinafter the same applies in this item), the total amount of expenses directly incurred to obtain that amount of dividends of surplus and similar distributions and the amount calculated pursuant to the method specified by Cabinet Order as the amount of expenses pertaining to that amount of dividends of surplus and similar distributions;

二the amount remaining after deducting, from the total amount of interest received, etc. (meaning interest that it receives (including anything specified by Cabinet Order as being equivalent thereto; hereinafter the same applies in this item); hereinafter the same applies in this item and item (xi), (b)) (excluding the amount of interest on deposits or savings (including those equivalent to those specified by Cabinet Order as prescribed in Article 2, paragraph (1), item (x) of the Income Tax Act) arising in the ordinary course of operations pertaining to its business, the amount of interest pertaining to loans of money made by a partially covered foreign affiliated corporation whose principal business is the lending of money (limited to one that has obtained a license or registration or any other similar disposition in its state of the head office under the provisions of the laws and regulations of its state of the head office with respect to engaging in the lending of money as a business) and whose officers or employees engage, in its state of the head office, in all of the operations that are found to be ordinarily necessary to properly carry out its business of lending money, and the amount of any other interest specified by Cabinet Order; hereinafter the same applies in this item), the total amount of expenses directly incurred to obtain that amount of interest received, etc.;

三the amount remaining after deducting, from the total amount of consideration for the lending of Securities, the total amount of expenses directly incurred to obtain that consideration;

四the amount obtained by subtracting, from the total amount of consideration for the transfer of Securities (excluding the amount of consideration for the transfer of shares, etc. of another corporation in the case where the ratio of the number or amount of shares, etc. of the other corporation held by the partially covered foreign affiliated corporation to the total number or total amount of its issued shares, etc. is 25 percent or more immediately before the transfer; hereinafter the same applies in this item), the total amount calculated pursuant to the method specified by Cabinet Order as the cost of the transfer of those Securities and the total amount of expenses directly incurred to obtain that consideration;

五the amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or the amount of loss pertaining to derivative transactions (meaning derivative transactions prescribed in Article 61-5, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this item and item (xi), (e)) (excluding the amount of profit or the amount of loss pertaining to derivative transactions specified by Order of the Ministry of Finance as derivative transactions conducted to reduce the losses listed in the items of Article 61-6, paragraph (1) of that Act, the amount of profit or the amount of loss pertaining to derivative transactions specified by Order of the Ministry of Finance that are conducted by a partially covered foreign affiliated corporation that engages, as a business, in acts equivalent to the acts listed in the items of Article 2, paragraph (22) of the Commodity Derivatives Transaction Act in accordance with the laws and regulations of its state of the head office (limited to one whose officers or employees engage, in its state of the head office, in all of the operations that are found to be ordinarily necessary to properly carry out the business pertaining to those acts), and the amount of profit or the amount of loss pertaining to any other derivative transactions specified by Order of the Ministry of Finance);

六the amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or the amount of loss arising from fluctuations in foreign exchange rates with respect to transactions it conducts or assets or liabilities it holds (excluding the amount of profit or the amount of loss arising in the ordinary course of operations pertaining to its business (excluding a business of conducting transactions specified by Cabinet Order));

七the amount of profit or the amount of loss arising from the investment, holding, transfer, or lending of, or any other act involving, assets that give rise to the amount of profit or the amount of loss pertaining to the amounts listed in the preceding items (including any amount of profit or amount of loss similar thereto) (excluding the amount of profit or the amount of loss pertaining to the amounts listed in those items and the amount of profit or the amount of loss pertaining to transactions specified by Order of the Ministry of Finance as transactions conducted to reduce the losses listed in the items of Article 61-6, paragraph (1) of the Corporation Tax Act);

七の二the amount obtained by subtracting the amount listed in (b) from the amount listed in (a):

イthe amount specified by Cabinet Order as the amount equivalent to the balance remaining after deducting the total amount of reinsurance premiums paid from the total amount of premium income;

ロthe amount specified by Cabinet Order as the amount equivalent to the balance remaining after deducting the total amount of reinsurance proceeds received from the total amount of insurance proceeds paid.

八the amount remaining after deducting, from the total amount of consideration for the lending of fixed assets (meaning fixed assets prescribed in Article 2, item (xxii) of the Corporation Tax Act, excluding those specified by Cabinet Order; hereinafter the same applies in this item and item (xi), (i)) (including acts of allowing the use of real property or rights existing on real property) (excluding the amount of consideration for the lending of fixed assets (excluding real property and rights existing on real property) that are mainly used in its state of the head office, the amount of consideration for the lending of real property or rights existing on real property located in its state of the head office (including acts of allowing the use thereof), and the amount of consideration for the lending of fixed assets by a partially covered foreign affiliated corporation that satisfies the requirements specified by Cabinet Order, such as the requirement that its officers or employees engage, in its state of the head office, in all of the operations that are found to be ordinarily necessary to properly carry out the lending of fixed assets (including acts of allowing the use of real property or rights existing on real property; hereinafter the same applies in this item and item (xi), (i)); hereinafter the same applies in this item), the total amount of expenses directly incurred to obtain that consideration (including the amount calculated pursuant to the method specified by Cabinet Order as the amount of depreciation allowances pertaining to fixed assets it holds);

九the amount remaining after deducting, from the total amount of royalties for industrial property rights or other rights relating to technology, production methods involving special technology or anything equivalent thereto (including rights to use those rights), or copyrights (including rights of publication, neighboring rights and anything equivalent thereto) (hereinafter referred to in this paragraph as "intangible assets, etc.") (excluding royalties for intangible assets, etc. pertaining to the results of research and development conducted by itself and any other royalties specified by Cabinet Order; hereinafter the same applies in this item), the total amount of expenses directly incurred to obtain those royalties (including the amount calculated pursuant to the method specified by Cabinet Order as the amount of depreciation allowances pertaining to intangible assets, etc. it holds);

十the amount obtained by subtracting, from the total amount of consideration for the transfer of intangible assets, etc. (excluding the amount of consideration for the transfer of intangible assets, etc. pertaining to the results of research and development conducted by itself and the amount of any other consideration specified by Cabinet Order; hereinafter the same applies in this item), the total amount of costs of the transfer of those intangible assets, etc. and the total amount of expenses directly incurred to obtain that consideration;

十一the amount remaining after deducting the amount listed in (l) for the relevant business year from the amount specified by Cabinet Order as the amount of income of the partially covered foreign affiliated corporation for each business year that would be calculated if there were none of the amounts listed in (a) through (k):

イthe amount of dividends of surplus and similar distributions it receives;

ロthe amount of interest received, etc.;

ハthe amount of consideration for the lending of Securities;

ニthe amount obtained by subtracting, from the total amount of consideration for the transfer of Securities, the total amount calculated pursuant to the method specified by Cabinet Order as the cost of the transfer of those Securities;

ホthe amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or the amount of loss pertaining to derivative transactions;

ヘthe amount calculated pursuant to the provisions of Order of the Ministry of Finance as the amount of profit or the amount of loss arising from fluctuations in foreign exchange rates with respect to transactions it conducts or assets or liabilities it holds;

トthe amount of profit or the amount of loss arising from the investment, holding, transfer, or lending of, or any other act involving, assets that give rise to the amount of profit or the amount of loss pertaining to the amounts listed in items (i) through (vi) (including any amount of profit or amount of loss similar thereto) (excluding the amount of profit or the amount of loss pertaining to the amounts listed in those items);

チthe amount listed in item (vii)-2;

リthe amount of consideration for the lending of fixed assets;

ヌroyalties received for intangible assets, etc.;

ルthe amount obtained by subtracting, from the total amount of consideration for the transfer of intangible assets, etc., the total amount of costs of the transfer of those intangible assets, etc.;

ヲthe amount calculated by multiplying the amount obtained by adding the amount of personnel expenses and other expenses specified by Cabinet Order to the amount specified by Cabinet Order as the amount of total assets, by 50 percent.

一the amount calculated pursuant to the method specified by Cabinet Order as the amount of profit pertaining to the capital equivalent to the excess, in the case where the amount equivalent to the parent company's equity, etc. of a partially covered foreign affiliated corporation whose issued shares, etc. are all held directly or indirectly by a single resident who is a specially-related shareholder, etc. and which satisfies the requirements specified by Cabinet Order (limited to one for which the ratio of the amount specified by Cabinet Order as the amount obtained by making adjustments to its net assets with regard to surplus and other matters (hereinafter referred to in this item as the "amount equivalent to the parent company's equity, etc.") to the amount specified by Cabinet Order as the amount of its total assets exceeds 70 percent) exceeds the amount specified by Cabinet Order by taking into consideration the amount of capital below which it may not fall under the laws and regulations of its state of the head office;

二the amount equivalent to the amount listed in paragraph (8), item (viii) that is obtained when the amount is calculated for the partially covered foreign affiliated corporation in accordance with the provisions of that item;

三the amount equivalent to the amount listed in paragraph (8), item (ix) that is obtained when the amount is calculated for the partially covered foreign affiliated corporation in accordance with the provisions of that item;

四the amount equivalent to the amount listed in paragraph (8), item (x) that is obtained when the amount is calculated for the partially covered foreign affiliated corporation in accordance with the provisions of that item;

五the amount equivalent to the amount listed in paragraph (8), item (xi) that is obtained when the amount is calculated for the partially covered foreign affiliated corporation in accordance with the provisions of that item.

一the amount listed in item (i) of the preceding paragraph;

二the sum of the total of the amounts listed in item (ii), item (iii) and item (v) of the preceding paragraph, and the amount obtained by making adjustments pursuant to the method specified by Cabinet Order, based on the amount listed in item (iv) of that paragraph (if that amount is less than zero, zero), with regard to the amount of the portion by which the amount listed in that item arising in each business year that began within seven years before the first day of the relevant business year fell below zero.

一the tax burden ratio for each business year is 20 percent or more;

二the partially applicable amount or the partially applicable amount for a financial affiliated corporation in each business year is 20 million yen or less;

三the ratio of the partially applicable amount or the partially applicable amount for a financial affiliated corporation in each business year to the amount specified by Cabinet Order as the amount equivalent to the amount of income based on the settlement of accounts for the relevant business year is 5 percent or less.

一a partially covered foreign affiliated corporation whose tax burden ratio for each business year concerned is less than 20 percent (excluding any partially covered foreign affiliated corporation to which either of the facts referred to in paragraph (12), item (ii) or item (iii) applies in the relevant business year (referred to in the following paragraph as a "partially covered foreign affiliated corporation exempt from attachment"));

二a covered affiliated foreign corporation whose tax burden ratio for each business year concerned is less than 20 percent;

三a specified foreign affiliated corporation whose tax burden ratio for each business year concerned is less than 27 percent.

一the amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held directly by the resident in the foreign corporation (meaning the number of shares, etc. held directly prescribed in Article 40-5, paragraph (1), item (i); the same applies in the following item and item (i) of the following paragraph), out of the taxable amount, partially taxable amount or partially taxable amount for a financial affiliated corporation pertaining to the foreign corporation that is included in gross revenue in the calculation of the amount of miscellaneous income for the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article;

二the amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held directly by the resident in the foreign corporation, out of the taxable amount, partially taxable amount or partially taxable amount for a financial affiliated corporation pertaining to the foreign corporation that was included in gross revenue in the calculation of the amount of miscellaneous income for each year within the three years preceding the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article (if there is an amount of dividends of surplus and similar distributions received from the foreign corporation in those years (limited to the portion of the amount to which the provisions of this paragraph were applied; hereinafter the same applies in this item), the balance remaining after deducting the amount equivalent to that amount of dividends of surplus and similar distributions; referred to in paragraph (3) as the "already-taxed amount").

一the amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held directly by the resident in the foreign corporation referred to in the preceding paragraph, out of the amount of dividends of surplus and similar distributions received by the foreign corporation referred to in the preceding paragraph from another foreign corporation in the year that includes the dividend date and in each year within the two years preceding that year (excluding those specified by Cabinet Order as the amount of dividends of surplus and similar distributions received before the first day of the business year of the other foreign corporation to which the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article apply) (if there is an amount of dividends of surplus and similar distributions received from the foreign corporation in each year within the two years preceding the year that includes the dividend date (referred to in (b) of the following item as "each year within the preceding two years") (limited to the portion, out of the amount to which the provisions of this paragraph were applied, corresponding to the amount of dividends of surplus and similar distributions received by the foreign corporation from the other foreign corporation; hereinafter referred to in this paragraph as the "amount of dividends, etc. to which the special rule applied"), the balance remaining after deducting the amount of dividends, etc. to which the special rule applied; referred to in the following paragraph as "indirect dividends, etc.");

二the sum of the following amounts:

イthe amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held indirectly by the resident referred to in that item in the other foreign corporation (meaning the number of shares, etc. held indirectly prescribed in Article 40-5, paragraph (2), item (ii), (a); the same applies in (b)), out of the taxable amount, partially taxable amount or partially taxable amount for a financial affiliated corporation pertaining to the other foreign corporation referred to in the preceding item that is included in gross revenue in the calculation of the amount of miscellaneous income for the year that includes the dividend date pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article;

ロthe amount specified by Cabinet Order as the portion corresponding to the number of shares, etc. held indirectly by the resident referred to in that item in the other foreign corporation, out of the taxable amount, partially taxable amount or partially taxable amount for a financial affiliated corporation pertaining to the other foreign corporation referred to in the preceding item that was included in gross revenue in the calculation of the amount of miscellaneous income for each year within the preceding two years pursuant to the provisions of paragraph (1), paragraph (8) or paragraph (10) of the preceding Article (if there is an amount of dividends, etc. to which the special rule applied that was received from the foreign corporation referred to in the preceding paragraph in each year within the preceding two years, the balance remaining after deducting that amount of dividends, etc. to which the special rule applied; referred to in the following paragraph as the "indirectly taxed amount").