①The provisions of Article 55 of the New Act on Special Measures Concerning Taxation apply to shares (including equity) of, or claims against, a specified corporation prescribed in paragraph (1) of that Article that a corporation transfers, on or after the Effective Date, through a qualified capital contribution in kind to a corporation receiving the capital contribution in kind that is a foreign corporation.

④The provisions of Article 57-3 of the New Act on Special Measures Concerning Taxation apply to corporation tax for business years of a corporation ending on or after the date specified in Article 1, item (xxv) of the Supplementary Provisions.

⑤In the case where a corporation filing a blue return that operates an electricity generation business prescribed in Article 2, paragraph (1), item (xiv) of the Electricity Business Act (Act No. 170 of 1964) has, on the date specified in Article 1, item (xxv) of the Supplementary Provisions, an amount of the reserve for reprocessing of spent nuclear fuel prescribed in Article 57-3, paragraph (1), item (ii) of the Former Act on Special Measures Concerning Taxation, an amount equivalent to the amount calculated by multiplying the amount of that reserve for reprocessing of spent nuclear fuel by the number of months in each business year and dividing the product by 180 (referred to as the "amount reversed in equal parts over fifteen years" in the following paragraph) is included in gross profit in calculating the amount of income for each business year (excluding a business year that falls under a consolidated business year) that includes any day within 15 years from the first day of the business year that includes that date (where the business year that includes the date specified in Article 1, item (xxv) of the Supplementary Provisions falls under a consolidated business year, the first day of that consolidated business year).

⑥In the case referred to in the preceding paragraph, if the amount reversed in equal parts over fifteen years exceeds the amount of the reserve for reprocessing of spent nuclear fuel as of the end of the business year (where, by that date, there is an amount that has been included, or has come to be included, in gross profit pursuant to the provisions of the following paragraph out of the amount of the reserve for reprocessing of spent nuclear fuel prescribed in that paragraph (including an amount included in gross profit pursuant to the provisions of Article 48, paragraph (7) of the Supplementary Provisions), or an amount that has been included in gross profit pursuant to the provisions of the preceding paragraph by the end of the preceding business year (where the business year that includes the day preceding the first day of that business year falls under a consolidated business year, the consolidated business year that includes that preceding day) (including an amount included in gross profit pursuant to the provisions of paragraph (5) of that Article), the amount remaining after deducting those amounts; the same applies hereinafter in this Article), the amount reversed in equal parts over fifteen years is to be the amount of that reserve for reprocessing of spent nuclear fuel.

⑦If a corporation to which the provisions of paragraph (5) apply comes to fall under any of the cases listed in the following items (excluding the case where it has transferred spent fuel prescribed in Article 2, paragraph (1) of the Act on the Implementation of Reprocessing, etc. of Spent Fuel in Nuclear Power Generation (Act No. 48 of 2005) (hereinafter referred to as "spent fuel" in this paragraph and paragraph (11)) to the merging corporation through a qualified merger), an amount equivalent to the amount specified in the relevant item is included in gross profit in calculating the amount of income for the business year that includes the date on which it came to fall under that case (in the case listed in item (ii), the business year that includes the day preceding the date of the merger).

⑧If a corporation to which the provisions of paragraph (5) apply has its approval for filing blue returns revoked, or submits a written notification stating that it will cease filing blue returns, by the day on which 14 years have elapsed from the first day of the business year that includes the date specified in Article 1, item (xxv) of the Supplementary Provisions (where the business year that includes the date specified in that item falls under a consolidated business year, the first day of that consolidated business year), the amount of the reserve for reprocessing of spent nuclear fuel as of the date on which the fact giving rise to the revocation of the approval occurred or the date on which the written notification was submitted (where the date on which the written notification was submitted is after the end of the business year in which the corporation ceased filing blue returns, the end of that business year) is, as specified by Cabinet Order, included in gross profit in calculating the amount of income for each business year from the business year that includes that date to the business year that includes the day preceding the day on which two years have elapsed from the first day of that business year (where the business year that includes the day preceding the day on which two years have elapsed from the first day of that business year (hereinafter referred to as the "date two years have passed" in this paragraph) falls under a consolidated business year, the business year that includes the day preceding the first day of the consolidated business year that first began during the period from the day following the first day of that business year to the date two years have passed). In this case, the provisions of paragraph (5), the preceding paragraph and paragraph (11) do not apply to that amount of the reserve for reprocessing of spent nuclear fuel.

⑨If a corporation to which the provisions of paragraph (5) apply is, in the case where the business year does not fall under a consolidated business year and the business year that includes the day preceding the first day of that business year fell under a consolidated business year, not a person who may file the tax return, etc. for that business year using a blue return (including the case where it has come to be a person who may not file the tax return, etc. for that business year using a blue return because its approval for filing blue returns has been revoked or it has submitted a written notification stating that it will cease filing blue returns), the amount of the reserve for reprocessing of spent nuclear fuel as of the end of that business year is included in gross profit in calculating the amount of income for that business year. In this case, the provisions of paragraph (5), the preceding two paragraphs and paragraph (11) do not apply.

⑩The number of months referred to in paragraph (5) is calculated according to the calendar, and a fraction of less than one month is counted as one month.

⑪If a corporation to which the provisions of paragraph (5) apply has transferred spent fuel to the merging corporation through a qualified merger (excluding the case prescribed in the first sentence of Article 48, paragraph (9) of the Supplementary Provisions), the amount of the reserve for reprocessing of spent nuclear fuel immediately before the qualified merger is to be taken over by that merging corporation. In this case, the amount of the reserve for reprocessing of spent nuclear fuel taken over by the merging corporation is deemed to be the amount of the reserve for reprocessing of spent nuclear fuel referred to in paragraph (5) that the merging corporation holds as of the date of the qualified merger (where the business year of the merging corporation that includes the date of the qualified merger falls under a consolidated business year, the amount of the reserve for reprocessing of spent nuclear fuel referred to in paragraph (5) of that Article).

⑫In the case referred to in the preceding paragraph or Article 48, paragraph (9) of the Supplementary Provisions, if the merging corporation referred to in those provisions (excluding one that falls under a consolidated corporation after the qualified merger) is not a person who may file the tax return, etc. for the business year that includes the date of the qualified merger using a blue return, the amount of the reserve for reprocessing of spent nuclear fuel as of the end of that business year is included in gross profit in calculating the amount of income for that business year.

⑬With regard to the application of the provisions of paragraph (5) to each business year on or after the business year that includes the date of the qualified merger (where the business year that includes the date of the qualified merger falls under a consolidated business year, each business year after that consolidated business year) of the merging corporation prescribed in paragraph (11) or Article 48, paragraph (9) of the Supplementary Provisions (excluding one that falls under a consolidated corporation after the qualified merger), the amount of the reserve for reprocessing of spent nuclear fuel prescribed in paragraph (5) is to include the amount of the reserve for reprocessing of spent nuclear fuel deemed to be held by the merging corporation pursuant to the provisions of paragraph (11) or paragraph (9) of that Article. In this case, with regard to the amount of the reserve for reprocessing of spent nuclear fuel deemed to be held by the merging corporation, the phrase "by the number of months in each business year and dividing the product by 180" in paragraph (5) is deemed to be replaced with "by the number of months in each business year (for the business year that includes the date of the qualified merger, the number of months in the period from that date to the end of the business year that includes that date) and dividing the product by the number of months obtained by deducting from 180 months the number of months in the elapsed period (meaning the period from the first day of the business year that includes the date specified in Article 1, item (xxv) of the Supplementary Provisions (where the business year that includes the date specified in that item falls under a consolidated business year, the first day of that consolidated business year) to the day preceding the date of the qualified merger)".