①The provisions of Article 66-9-2, paragraph (1), paragraph (2), item (iii), paragraph (3) and paragraph (4) of the New Act on Special Measures Concerning Taxation apply to the amount of applicable income prescribed in paragraph (1) of that Article for business years of a specified foreign corporation prescribed in that paragraph beginning on or after the Effective Date and to the taxable amount prescribed in that paragraph pertaining to that amount of applicable income, and the provisions then in force continue to govern the amount of applicable retained income prescribed in Article 66-9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation for business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date and the taxable retained amount prescribed in that paragraph pertaining to that amount of applicable retained income.

②The provisions of Article 66-9-3, paragraphs (1) and (3) of the New Act on Special Measures Concerning Taxation apply to the amount of foreign country's corporate tax prescribed in paragraph (1) of that Article pertaining to the taxable amount prescribed in that paragraph for business years of a specified foreign corporation prescribed in that paragraph beginning on or after the Effective Date, and the provisions then in force continue to govern the amount of foreign country's corporate tax prescribed in Article 66-9-7, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to the taxable retained amount prescribed in that paragraph for business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date.

③The provisions of Article 66-9-4 of the New Act on Special Measures Concerning Taxation apply in the case where a domestic corporation that is a specially-related shareholder, etc. prescribed in paragraph (2) of that Article has an amount of dividends of surplus, etc. prescribed in paragraph (1) of that Article that it receives from a specified foreign corporation prescribed in paragraph (2) of that Article (limited to an amount pertaining to business years of that specified foreign corporation beginning on or after the Effective Date), and the provisions then in force continue to govern the case where any of the facts listed in the items of Article 66-9-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation has arisen with respect to a specified foreign corporation or a foreign affiliated corporation prescribed in that paragraph pertaining to a domestic corporation that is a specially-related shareholder, etc. prescribed in that paragraph (limited to a fact pertaining to business years of that specified foreign corporation or foreign affiliated corporation that began before the Effective Date).

④Out of the taxable retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation for business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date (limited to an amount included in gross profit in calculating the amount of income for the business year prescribed in Article 66-9-4, paragraph (3), item (i) of the New Act on Special Measures Concerning Taxation of a domestic corporation that is a specially-related shareholder, etc. prescribed in that item (hereinafter referred to as the "business year of dividends, etc." in this paragraph); the same applies hereinafter in this paragraph) or the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation (including an amount deemed to be the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation pursuant to the provisions of Article 66-8, paragraph (3) of the Former Act on Special Measures Concerning Taxation as applied with the replacement of terms pursuant to the provisions of paragraph (2) or paragraph (3) of Article 66-9-8 of the Former Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph), the amount of the part corresponding to each business year within the preceding ten years prescribed in Article 66-9-4, paragraph (3), item (ii) of the New Act on Special Measures Concerning Taxation of a domestic corporation that is a specially-related shareholder, etc. prescribed in that item (hereinafter referred to as "each business year within the preceding ten years" in this paragraph) (excluding the amount equivalent to the amount of dividends of surplus, etc. prescribed in that item that is deducted pursuant to the provisions of that item) is deemed to be the amounts listed in the items of paragraph (3) of that Article for the business year of dividends, etc. or each business year within the preceding ten years that corresponds to the period of the business year or consolidated business year to which the taxable retained amount or taxed retained amount of that domestic corporation pertains, and the provisions of paragraphs (1) through (3) of that Article apply.

⑤With regard to the amount of dividends of surplus, etc. prescribed in Article 66-9-2, paragraph (1) of the New Act on Special Measures Concerning Taxation (limited to an amount pertaining to business years of that specified foreign corporation that began before the Effective Date; the same applies hereinafter in this paragraph) that a domestic corporation that is a specially-related shareholder, etc. prescribed in Article 66-9-2, paragraph (1) of the New Act on Special Measures Concerning Taxation receives, in a business year beginning on or after the Effective Date, from a specified foreign corporation prescribed in Article 66-9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to that domestic corporation, the provisions of Article 23-2 of the New Corporation Tax Act do not apply. In this case, with regard to the part pertaining to that amount of dividends of surplus, etc. out of the amount of foreign country's corporate tax (meaning foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act; the same applies hereinafter in this paragraph) imposed on the income of that specified foreign corporation and the amount of foreign country's corporate tax imposed on the income of a foreign second-tier subsidiary prescribed in Article 69, paragraph (11) or Article 81-15, paragraph (11) of the Former Corporation Tax Act pertaining to that specified foreign corporation, in each business year or each consolidated business year of that domestic corporation beginning on or before the day on which three years have elapsed from the Effective Date, the provisions of Article 28 and Article 69, paragraphs (8), (11) and (13) and paragraphs (15) through (18) of the Former Corporation Tax Act, or Article 81-5 and Article 81-15, paragraphs (8) and (9), paragraphs (11) through (13) and paragraphs (15) through (17) of the Former Corporation Tax Act, remain in force.

⑥With regard to the amount of dividends of surplus, etc. prescribed in Article 66-9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation (limited to an amount pertaining to business years of that specified foreign corporation beginning on or after the Effective Date; the same applies hereinafter in this paragraph) that a domestic corporation that is a specially-related shareholder, etc. prescribed in Article 66-9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation received, in a business year that began before the Effective Date, from a specified foreign corporation prescribed in Article 66-9-2, paragraph (1) of the New Act on Special Measures Concerning Taxation pertaining to that domestic corporation (limited to one that falls under a foreign subsidiary prescribed in Article 23-2, paragraph (1) of the New Corporation Tax Act; the same applies hereinafter in this paragraph), the provisions of Article 23-2 of the New Corporation Tax Act apply notwithstanding the provisions of Article 6 of the Supplementary Provisions. In this case, the provisions of Article 12, paragraph (2) or Article 16, paragraph (2) of the Supplementary Provisions do not apply to the part pertaining to that amount of dividends of surplus, etc. out of the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act imposed on the income of a foreign subsidiary prescribed in Article 69, paragraph (8) or Article 81-15, paragraph (8) of the Former Corporation Tax Act and of a foreign second-tier subsidiary prescribed in Article 69, paragraph (11) or Article 81-15, paragraph (11) of the Former Corporation Tax Act.

⑦With regard to the application of the provisions of the Former Corporation Tax Act in the case where the provisions of the first sentence of the preceding paragraph apply, the phrase "excluded)" in Article 67, paragraph (3), item (ii) of the Former Corporation Tax Act is deemed to be replaced with "excluded) and the amount that was not included in gross profit in calculating the amount of income for that business year pursuant to the provisions of Article 23-2 (Exclusion of Dividends, etc. Received from Foreign Subsidiaries from Gross Profit) (including the case where it is applied with the replacement of terms pursuant to the provisions of the first sentence of Article 66-9-4, paragraph (2) (Exclusion of Dividends of Surplus, etc. Received from Specified Foreign Corporations from Gross Profit, etc.) of the Act on Special Measures Concerning Taxation) as applied pursuant to the provisions of the first sentence of Article 45, paragraph (6) (Transitional Measures Concerning Special Provisions on Taxation on Income of Specified Foreign Corporations of Domestic Corporations That Are Specially-Related Shareholders, etc.) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009)".

①The provisions of Article 66-10, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to assets for experimental research prescribed in that paragraph that a corporation acquires or manufactures on or after the date specified in Article 1, item (ii) of the Supplementary Provisions, and the provisions then in force continue to govern assets for experimental research prescribed in Article 66-10, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired or manufactured before that date.

②In the case referred to in the preceding paragraph, with regard to the application of the provisions of Article 66-10 of the New Act on Special Measures Concerning Taxation to a mining and manufacturing technology research association which, pursuant to the provisions of Article 6 of the Supplementary Provisions of the Act Partially Amending the Act on Special Measures for Industrial Revitalization, etc. to Promote Innovation, etc. in Industrial Activities in Japan (hereinafter referred to as the "Industrial Revitalization Act, etc. Amendment Act" in this paragraph), is deemed to be a research and development partnership (meaning a research and development partnership prescribed in Article 2, paragraph (1) of the Research and Development Partnerships Act (Act No. 81 of 1961) as amended by the provisions of Article 2 of the Industrial Revitalization Act, etc. Amendment Act) (a mining and manufacturing technology research association here meaning a mining and manufacturing technology research association prescribed in Article 2 of the Act on Mining and Manufacturing Technology Research Associations prior to the amendment by the provisions of Article 2 of the Industrial Revitalization Act, etc. Amendment Act), the phrase "imposes expenses" in paragraph (1) of that Article is deemed to be replaced with "makes an imposition of expenses (including one deemed to be an imposition of expenses under the provisions of Article 9, paragraph (1) of the Research and Development Partnerships Act pursuant to the provisions of Article 11 of the Supplementary Provisions of the Act Partially Amending the Act on Special Measures for Industrial Revitalization, etc. to Promote Innovation, etc. in Industrial Activities in Japan)".

The provisions of Article 66-13, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to the amount of loss incurred in a business year of a corporation ending on or after February 1, 2009, and the provisions then in force continue to govern the amount of loss incurred in a business year prescribed in the main clause of Article 66-13, paragraph (1) of the Former Act on Special Measures Concerning Taxation of a corporation that ended before that date.

①The provisions of Article 67-14, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to corporation tax for business years ending on or after the Effective Date of a specific purpose company prescribed in that paragraph, and the provisions then in force continue to govern corporation tax for business years that ended before the Effective Date of a specific purpose company prescribed in Article 67-14, paragraph (1) of the Former Act on Special Measures Concerning Taxation.

②The provisions of Article 67-14, paragraph (3) of the New Act on Special Measures Concerning Taxation (limited to the part concerning the row for item (i) of the table in Article 42-3-2, paragraph (1) in the table in that paragraph) apply to corporation tax for business years ending on or after the Effective Date of a specific purpose company prescribed in Article 67-14, paragraph (1) of the New Act on Special Measures Concerning Taxation (referred to as a "specific purpose company" in the following paragraph).

③The provisions of Article 67-14, paragraph (3) of the New Act on Special Measures Concerning Taxation (limited to the part concerning the row for Article 66-13, paragraph (1), item (i) in the table in that paragraph) apply to corporation tax for business years of a specific purpose company ending on or after February 1, 2009.

①The provisions of Article 67-15, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to corporation tax for business years ending on or after the Effective Date of an investment corporation prescribed in that paragraph, and the provisions then in force continue to govern corporation tax for business years that ended before the Effective Date of an investment corporation prescribed in Article 67-15, paragraph (1) of the Former Act on Special Measures Concerning Taxation.

②The provisions of Article 67-15, paragraph (4) of the New Act on Special Measures Concerning Taxation (limited to the part concerning the row for item (i) of the table in Article 42-3-2, paragraph (1) in the table in that paragraph) apply to corporation tax of an investment corporation prescribed in Article 67-15, paragraph (2) of the New Act on Special Measures Concerning Taxation (referred to as an "investment corporation" in the following paragraph) for business years ending on or after the Effective Date.

③The provisions of Article 67-15, paragraph (4) of the New Act on Special Measures Concerning Taxation (limited to the part concerning the row for Article 66-13, paragraph (1), item (i) in the table in that paragraph) apply to corporation tax of an investment corporation for business years ending on or after February 1, 2009.

The provisions of Article 67-16 of the New Act on Special Measures Concerning Taxation apply to domestic source income prescribed in Article 138 of the Corporation Tax Act that a foreign corporation referred to in paragraph (1) of that Article has on or after the Effective Date.

①The provisions of Article 67-17, paragraph (3) of the New Act on Special Measures Concerning Taxation apply to redemption gains prescribed in that paragraph on discount bonds prescribed in that paragraph that a foreign corporation issues on or after the Effective Date.

②The provisions of Article 67-17, paragraph (4) of the New Act on Special Measures Concerning Taxation apply to redemption gains prescribed in that paragraph that a foreign corporation listed in Article 141, items (ii) through (iv) of the Corporation Tax Act receives on discount bonds prescribed in that paragraph that are issued on or after the Effective Date.