This Act comes into effect on April 1, 1964.

Unless otherwise provided for, the provisions of Chapter II of the Act on Special Measures Concerning Taxation as amended (hereinafter referred to as "the New Act") apply to income tax for 1964 and subsequent years, and the provisions then in force continue to govern income tax for 1963 and prior years.

The provisions then in force continue to govern dividend income from distributions of proceeds of securities investment trusts that were to have been received before April 1, 1964 (hereinafter referred to as "the Effective Date").

①The provisions of Article 11 of the New Act apply to the calculation of the amount of depreciation expenses of rationalization machinery, etc. prescribed in paragraph (1) of that Article that an individual has acquired or manufactured and used for business on or after the Effective Date, and the provisions then in force continue to govern the calculation of the amount of depreciation expenses of rationalization machinery, etc. prescribed in Article 11, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment (hereinafter referred to as "the Former Act") in the case where an individual uses for business that rationalization machinery, etc. which the individual acquired or manufactured before that date.

②The provisions then in force continue to govern the calculation of the amount of depreciation expenses of approved machinery and equipment, etc. prescribed in Article 12, paragraph (1) of the Former Act or machinery, etc. for development research prescribed in paragraph (2) of that Article in the case where an individual uses that machinery and equipment, etc. or machinery, etc. for development research, which the individual acquired or manufactured before the Effective Date, for the experimental research or development research prescribed in those provisions.

③The provisions of Article 15 of the New Act apply to the calculation of the amount of depreciation expenses of machinery and equipment for exploration prescribed in paragraph (1) of that Article that an individual has acquired or manufactured and used for the exploration of new mineral deposits prescribed in that paragraph on or after the Effective Date, and the provisions then in force continue to govern the calculation of the amount of depreciation expenses of machinery and equipment for exploration prescribed in Article 15, paragraph (1) of the Former Act in the case where an individual uses that machinery and equipment for exploration, which the individual acquired or manufactured before that date, for the exploration of new mineral deposits prescribed in that paragraph.

④The provisions of Article 18 of the New Act apply to expenditures that an individual has made on or after the Effective Date, and the provisions then in force continue to govern expenditures made before that date.

If the total revenue of an individual from export transactions conducted, in each year that includes a day within the designated period prescribed in Article 21-2, paragraph (1) of the Former Act, within that designated period exceeds the amount calculated by multiplying the base export amount prescribed in that paragraph by the number of months of that designated period falling within the period during which the individual operated a business in that year and dividing the product by 12, or in any other case where the individual falls under the case specified by Cabinet Order prescribed in that paragraph, the provisions of that Article remain in force with respect to the individual's export transactions within the designated period in that year.

The provisions of Article 22 of the Former Act remain in force with respect to the inclusion in gross revenue of the portion of the amounts included in necessary expenses pursuant to the provisions of Article 21, paragraph (1), Article 21-2, paragraph (1) or Article 21-3, paragraph (1) of the Former Act with regard to transactions listed in Article 21, paragraph (1), item (iii) or items (v) through (ix) of the Former Act or indirect technology export transactions prescribed in Article 21-3, paragraph (1) of the Former Act conducted by an individual before the Effective Date that relates to transactions in goods, or in industrial property rights, etc. prescribed in Article 21, paragraph (1), item (i) of the Former Act, for which the certification prescribed in Article 22 of the Former Act was not made.

①If the certification prescribed in Article 23, paragraph (1) of the Former Act has been made for transactions listed in the items of that paragraph that an individual conducted before the Effective Date, the provisions of that paragraph through paragraph (5) of that Article remain in force with respect to those transactions.

②If, before the Effective Date, payment was made by foreign means of payment prescribed in Article 23, paragraph (6) of the Former Act as consideration for a transaction deemed not to be included in export transactions pursuant to the provisions of Article 21, paragraph (2) of the Former Act (including as applied mutatis mutandis pursuant to Article 21-3, paragraph (3) of the Former Act), or for an export relating to that transaction, or for a transaction deemed not to be included in technology export transactions, and the certification prescribed in that paragraph was made, and the provisions of Article 21, paragraph (1), Article 21-2, paragraph (1) or Article 21-3, paragraph (1) of the Former Act would have applied to that transaction, the provisions of Article 23, paragraph (6) of the Former Act remain in force with respect to the inclusion in necessary expenses of an amount equivalent to the amount to be included in necessary expenses as prescribed in that paragraph with regard to that transaction.

①If the total revenue of an individual from export transactions and technology export transactions conducted, in each year that includes a day within the designated period prescribed in Article 21-2, paragraph (1) of the Former Act, within that designated period exceeds the base export amount for the designated period prescribed in Article 23-2, paragraph (1) of the Former Act and the export amount ratio prescribed in that paragraph for that year exceeds the base export amount ratio prescribed in that paragraph, or in any other case specified by Cabinet Order prescribed in that paragraph, the provisions of that Article remain in force with respect to the calculation of the amount to be included in necessary expenses as depreciation expenses for that year for fixed assets prescribed in that paragraph. In this case, with regard to the application of the provisions of that Article to income tax of an individual for 1964, the phrase "Articles 11 through 17" in paragraph (1) of that Article is deemed to be replaced with "Articles 11 through 17, or Articles 11 through 13-2 or Articles 14 through 17 of the Act on Special Measures Concerning Taxation as amended by the Act Partially Amending the Act on Special Measures Concerning Taxation (Act No. 24 of 1964; hereinafter referred to as the 'Amending Act')", and the phrase "that Act" with "the Income Tax Act".

②With regard to the application of the provisions of Article 13-3, paragraphs (1) and (2) of the New Act to fixed assets to which the provisions of Article 23-2, paragraph (1) of the Former Act, which remain in force pursuant to the provisions of the preceding paragraph, apply and to which the provisions of Article 13-3, paragraph (1) of the New Act apply, the phrase "through Article 13" in paragraph (1) of that Article is deemed to be replaced with "through the preceding Article"; the phrase "if the provisions of paragraph (1) of the preceding Article apply, the provisions of that paragraph" with "if the provisions of Article 23-2, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment by the Act Partially Amending the Act on Special Measures Concerning Taxation (Act No. 24 of 1964; hereinafter referred to as the 'Amending Act'), which remain in force pursuant to the provisions of Article 10, paragraph (1) of the Supplementary Provisions of that Act, apply, the provisions of that paragraph"; the phrase "pursuant to the provisions of Article 10, paragraph (2) of that Act" with "pursuant to the provisions of Article 10, paragraph (2) of the Income Tax Act"; the phrase "if the provisions of paragraph (1) of the preceding Article apply, the total depreciation limit prescribed in that paragraph calculated pursuant to the provisions of that paragraph" with "if the provisions of Article 23-2, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment by the Amending Act, which remain in force pursuant to the provisions of Article 10, paragraph (1) of the Supplementary Provisions of the Amending Act, apply, the limit on depreciation expenses that may be included in necessary expenses pursuant to the provisions of that paragraph"; and the phrase "is less than the total depreciation limit for overseas transactions, etc." in paragraph (2) of that Article with "is less than the total depreciation limit for overseas transactions, etc. (excluding the amount specified by Cabinet Order out of the limit on depreciation expenses that may be included in necessary expenses pursuant to the provisions of Article 23-2, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment by the Amending Act, which remain in force pursuant to the provisions of Article 10, paragraph (1) of the Supplementary Provisions of the Amending Act)".

①In the case where an individual prescribed in the items of Article 23-3, paragraph (1) of the Former Act has come to fall under the case listed in any of those items, the provisions of that Article remain in force with respect to the amount to be included in necessary expenses as depreciation expenses for the year that includes the day on which the individual came to fall under that case for fixed assets prescribed in that paragraph that the individual holds as of December 31 of that year. In this case, the provisions of the second sentence of paragraph (1) of the preceding Article apply mutatis mutandis.

②The provisions of paragraph (2) of the preceding Article apply mutatis mutandis in the case where the provisions of Article 13-3, paragraphs (1) and (2) of the New Act are applied to fixed assets to which the provisions of Article 23-3, paragraph (1) of the Former Act, which remain in force pursuant to the provisions of the preceding paragraph, apply and to which the provisions of Article 13-3, paragraph (1) of the New Act apply. In this case, the phrase "Article 10, paragraph (1) of the Supplementary Provisions" in paragraph (2) of the preceding Article is deemed to be replaced with "Article 11, paragraph (1) of the Supplementary Provisions", the phrase "Article 23-2, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment" with "Article 23-3, paragraph (1) of the Act on Special Measures Concerning Taxation prior to amendment", and the phrase "limit on depreciation expenses that may be included" with "amount of depreciation expenses to be included".

Unless otherwise provided for, the provisions of Chapter III of the New Act apply to corporation tax of a corporation (including an association or foundation without juridical personality prescribed in Article 1, paragraph (2) of the Corporation Tax Act (Act No. 28 of 1947); the same applies hereinafter) for business years ending on or after the Effective Date, and the provisions then in force continue to govern corporation tax of a corporation for business years ending before that date.

The provisions of Article 42 of the New Act apply to corporation tax of a corporation for business years beginning on or after the Effective Date, or beginning before the Effective Date and ending on or after September 30, 1964, and the provisions then in force continue to govern corporation tax of a corporation for business years that ended before the Effective Date; provided, however, that with regard to the application of the provisions of that Article to corporation tax for business years beginning before that date and ending on or after September 30 of that year, the phrase "19 percent" in paragraph (1) of that Article is deemed to be replaced with "19.5 percent", the phrase "22 percent" with "23 percent", and the phrase "26 percent" with "27 percent".

①The provisions of Article 43 of the New Act apply to the calculation of the allowable depreciation amount of rationalization machinery, etc. prescribed in paragraph (1) of that Article that a corporation has acquired or manufactured and used for business on or after the Effective Date, and the provisions then in force continue to govern the calculation of the allowable depreciation amount of rationalization machinery, etc. prescribed in Article 43, paragraph (1) of the Former Act in the case where a corporation uses for business that rationalization machinery, etc. which it acquired or manufactured before that date.

②The provisions then in force continue to govern the calculation of the allowable depreciation amount of approved machinery and equipment, etc. prescribed in Article 44, paragraph (1) of the Former Act or machinery, etc. for development research prescribed in paragraph (2) of that Article in the case where a corporation uses that machinery and equipment, etc. or machinery, etc. for development research, which it acquired or manufactured before the Effective Date, for the experimental research or development research prescribed in those provisions.

③The provisions of Article 48 of the New Act apply to the calculation of the allowable depreciation amount of machinery and equipment for exploration prescribed in paragraph (1) of that Article that a corporation has acquired or manufactured and used for the exploration of new mineral deposits prescribed in that paragraph on or after the Effective Date, and the provisions then in force continue to govern the calculation of the allowable depreciation amount of machinery and equipment for exploration prescribed in Article 48, paragraph (1) of the Former Act in the case where a corporation uses that machinery and equipment for exploration, which it acquired or manufactured before that date, for the exploration of new mineral deposits prescribed in that paragraph.

④The provisions of Article 52 of the New Act apply to expenditures that a corporation has made on or after the Effective Date, and the provisions then in force continue to govern expenditures made before that date.

If the total revenue of a corporation from export transactions conducted, in each business year that includes a day within the designated period prescribed in Article 55-2, paragraph (1) of the Former Act, within that designated period exceeds the base export amount for the designated period prescribed in that paragraph, or in any other case where the corporation falls under the case specified by Cabinet Order prescribed in that paragraph, the provisions of that Article remain in force with respect to export transactions within the designated period in that business year.

The provisions of Article 56 of the Former Act remain in force with respect to the inclusion in gross profit of the portion of the amounts included in deductible expenses pursuant to the provisions of Article 55, paragraph (1), Article 55-2, paragraph (1) or Article 55-3, paragraph (1) of the Former Act with regard to transactions listed in Article 55, paragraph (1), item (iii) or items (v) through (ix) of the Former Act or indirect technology export transactions prescribed in Article 55-3, paragraph (1) of the Former Act conducted by a corporation before the Effective Date that relates to transactions in goods, or in industrial property rights, etc. prescribed in Article 55, paragraph (1), item (i) of the Former Act, for which the certification prescribed in Article 56 of the Former Act was not made. In this case, with regard to the application of the provisions of paragraph (3) of that Article to corporation tax of a corporation for business years ending on or after the Effective Date, the phrase "15 percent" in that paragraph is deemed to be replaced with "20 percent".

If the grounds prescribed in Article 56-2, paragraph (1) of the Former Act have arisen with regard to a corporation prescribed in that paragraph, the provisions of that Article remain in force with respect to requests for reassessment.

①If the certification prescribed in Article 57, paragraph (1) of the Former Act has been made for transactions listed in the items of that paragraph that a corporation conducted before the Effective Date, the provisions of that paragraph through paragraph (4) of that Article remain in force with respect to those transactions.

②If, before the Effective Date, payment was made by foreign means of payment prescribed in Article 57, paragraph (5) of the Former Act as consideration for a transaction deemed not to be included in export transactions pursuant to the provisions of Article 55, paragraph (3) of the Former Act (including as applied mutatis mutandis pursuant to Article 55-3, paragraph (3) of the Former Act), or for an export relating to that transaction, or for a transaction deemed not to be included in technology export transactions, and the certification prescribed in that paragraph was made, and the provisions of Article 55, paragraph (1), Article 55-2, paragraph (1) or Article 55-3, paragraph (1) of the Former Act would have applied to that transaction, the provisions of Article 57, paragraph (5) of the Former Act remain in force with respect to the inclusion in deductible expenses of an amount equivalent to the amount to be included in deductible expenses as prescribed in that paragraph with regard to that transaction.

If the grounds prescribed in Article 57-2, paragraph (1) of the Former Act have arisen with regard to a corporation prescribed in that paragraph, the provisions of that Article remain in force with respect to the inclusion in gross profit of the deducted amount prescribed in that paragraph.

①If the total revenue of a corporation from export transactions and technology export transactions conducted, in each business year that includes a day within the designated period prescribed in Article 55-2, paragraph (1) of the Former Act, within that designated period exceeds the base export amount for the designated period prescribed in Article 57-3, paragraph (1) of the Former Act and the export amount ratio prescribed in that paragraph for that business year exceeds the base export amount ratio prescribed in that paragraph, or in any other case where the corporation falls under the case specified by Cabinet Order prescribed in that paragraph, the provisions of that Article remain in force with respect to the calculation of the allowable depreciation amount for that business year of fixed assets prescribed in that paragraph. In this case, with regard to the application of the provisions of that Article to corporation tax of a corporation for business years ending on or after the Effective Date, the phrase "Articles 43 through 51" in paragraph (1) of that Article is deemed to be replaced with "Articles 43 through 51, or Articles 43 through 46 or Articles 47 through 51 of the Act on Special Measures Concerning Taxation as amended by the Amending Act".

②With regard to the application of the provisions of Article 46-2, paragraph (1) of the New Act to fixed assets to which the provisions of Article 57-3, paragraph (1) of the Former Act, which remain in force pursuant to the provisions of the preceding paragraph, apply and to which the provisions of Article 46-2, paragraph (1) of the New Act apply, the phrase "through Article 45" in that paragraph is deemed to be replaced with "through the preceding Article", the phrase "the provisions of the preceding Article" with "the provisions of Article 57-3 of the Act on Special Measures Concerning Taxation prior to amendment by the Amending Act, which remain in force pursuant to the provisions of Article 23, paragraph (1) of the Supplementary Provisions of the Amending Act", and the phrase "the amount equivalent to one-third" with "the amount calculated by multiplying by the ratio".

①In the case where a corporation prescribed in the items of Article 57-4, paragraph (1) of the Former Act has come to fall under the case listed in any of those items, the provisions of that Article remain in force with respect to the calculation of the allowable depreciation amount for the business year that includes the day on which the corporation came to fall under that case of fixed assets prescribed in that paragraph that the corporation holds at the end of that business year. In this case, the provisions of the second sentence of paragraph (1) of the preceding Article apply mutatis mutandis.

②With regard to fixed assets to which the provisions of Article 57-4, paragraph (1) of the Former Act, which remain in force pursuant to the provisions of the preceding paragraph, apply and to which the provisions of Article 46-2 of the New Act apply, for the application of the provisions of that paragraph to them, the phrase "through Article 45" in that paragraph is deemed to be replaced with "through the preceding Article", the phrase "the provisions of the preceding Article" with "the provisions of Article 57-4 of the Act on Special Measures Concerning Taxation prior to amendment by the Amending Act, which remain in force pursuant to the provisions of Article 24, paragraph (1) of the Supplementary Provisions of the Amending Act", and the phrase "the sum of the allowable depreciation amount (where there is a depreciation shortfall prescribed in the provisions of that Act and orders based on that Act, the amount obtained by deducting the amount equivalent to that depreciation shortfall; the same applies hereinafter in this paragraph) and the amount calculated by multiplying that allowable depreciation amount (where the provisions of that Article apply to those fixed assets, the amount obtained by deducting the amount equivalent to one-third prescribed in paragraph (1) of that Article) by the base overseas transaction ratio (where there is an amount equivalent to the depreciation shortfall so deducted, the amount obtained by adding that amount)" with "the sum of the allowable depreciation amount and the amount calculated by multiplying the allowable depreciation amount calculated in the case where the provisions of Articles 57-3 and 57-4 of that Act are not applied to those fixed assets (where there is a depreciation shortfall prescribed in the provisions of the Corporation Tax Act and orders based on that Act, the amount obtained by deducting the amount equivalent to that depreciation shortfall) by the base overseas transaction ratio".

The provisions of Article 66-3 of the New Act apply to corporation tax in the case where a corporation has carried out a merger prescribed in Article 66-2, paragraph (1) of the New Act on or after the Effective Date, and the provisions then in force continue to govern corporation tax in the case where a corporation carried out a merger prescribed in Article 66-2, paragraph (1) of the Former Act before that date.

The provisions of Articles 77, 77-2, 79 and 80-2 of the New Act apply to registration tax on registrations made on or after the Effective Date, and the provisions then in force continue to govern registration tax on registrations made before that date.