①The provisions of Article 68-43 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 consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent 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 68-53 of the New Act on Special Measures Concerning Taxation apply to corporation tax for consolidated business years of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation ending on or after the date specified in Article 1, item (xxv) of the Supplementary Provisions.

⑤In the case where a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation that operates an electricity generation business prescribed in Article 2, paragraph (1), item (xiv) of the Electricity Business Act 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 68-53, 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 consolidated 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 consolidated income for each consolidated business year that includes any day within 15 years from the first day of the consolidated business year that includes that date (where the business year that includes the date specified in Article 1, item (xxv) of the Supplementary Provisions does not fall under a consolidated business year, the first day of that 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 consolidated 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 34, 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 consolidated business year (where the business year that includes the day preceding the first day of that consolidated business year does not fall under a consolidated business year, the 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 consolidated parent corporation or its consolidated subsidiary 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 (hereinafter referred to as "spent fuel" in this paragraph and paragraph (9)) 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 consolidated income for the consolidated business year that includes the date on which it came to fall under that case (in the case listed in item (ii), the consolidated business year that includes the day preceding the date of the merger prescribed in that item).

⑧The 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.

⑨If a consolidated parent corporation or its consolidated subsidiary corporation to which the provisions of paragraph (5) apply has transferred spent fuel to the merging corporation through a qualified merger (for a qualified merger in which a consolidated subsidiary corporation is the merged corporation, limited to that qualified merger in the case where the date of the qualified merger is the first day of the consolidated parent corporation business year), 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 that paragraph 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 is a business year that does not fall under a consolidated business year, the amount of the reserve for reprocessing of spent nuclear fuel referred to in Article 34, paragraph (5) of the Supplementary Provisions).

⑩With regard to the application of the provisions of paragraph (5) to each consolidated business year on or after the consolidated business year that includes the date of the qualified merger (where the business year that includes the date of the qualified merger does not fall under a consolidated business year, each consolidated business year after that business year) of the merging corporation prescribed in the preceding paragraph or Article 34, paragraph (11) of the Supplementary Provisions (limited to 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 the preceding paragraph or paragraph (11) 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 consolidated business year and dividing the product by 180" in paragraph (5) is deemed to be replaced with "by the number of months in each consolidated business year (for the consolidated 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 consolidated 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 consolidated 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 does not fall under a consolidated business year, the first day of that business year) to the day preceding the date of the qualified merger)".

⑪Necessary matters concerning the calculation of the individual income amount or individual loss amount prescribed in Article 81-18, paragraph (1) of the Corporation Tax Act in the case where there is an amount to be included in gross profit pursuant to the provisions of paragraph (5) or paragraph (7) are specified by Cabinet Order.