This Act comes into effect on April 1, 2010; provided, however, that the provisions set forth in the following items come into effect on the dates specified respectively in those items:

Except as otherwise provided, the provisions of Chapter II of the Act on Special Measures Concerning Taxation as amended by Article 18 (hereinafter referred to as the "New Act on Special Measures Concerning Taxation") apply to income tax for 2010 and subsequent years, and the provisions then in force continue to govern income tax for 2009 and prior years.

With regard to the application of the provisions of the October Former Corporation Tax Act, as applied with the relevant terms and phrases replaced pursuant to the provisions of Article 3-3, paragraph (5), Article 6, paragraph (3) (including as applied mutatis mutandis pursuant to paragraph (13) of that Article), Article 8-3, paragraph (5), Article 9-2, paragraph (4), Article 41-9, paragraph (4) and Article 41-12, paragraph (4) of the Act on Special Measures Concerning Taxation before the amendment by Article 18 (hereinafter referred to as the "Former Act on Special Measures Concerning Taxation" through Article 130 of the Supplementary Provisions), to a domestic corporation prescribed in those provisions that dissolved (excluding dissolution due to a merger and a specified trust dissolution prescribed in Article 92, paragraph (2) of the October Former Corporation Tax Act) on or before September 30, 2010, the provisions then in force continue to govern.

The provisions of Article 4-4, paragraph (3) of the New Act on Special Measures Concerning Taxation apply to the termination or partial cancellation of a securities investment trust prescribed in that paragraph on or after January 1, 2010, and the provisions then in force continue to govern the termination or partial cancellation of a securities investment trust prescribed in Article 4-4, paragraph (3) of the Former Act on Special Measures Concerning Taxation before that date.

①A written application for a tax exemption for book-entry government bonds prescribed in Article 5-2, paragraph (1), item (i), (a) of the Former Act on Special Measures Concerning Taxation or a written application for a tax exemption for book-entry municipal bonds prescribed in item (ii), (a) of that paragraph that was submitted before the Effective Date (limited to one where, after the submission of that written application for a tax exemption for book-entry government bonds or written application for a tax exemption for book-entry municipal bonds or of a return prescribed in paragraph (10) or (11) of that Article that was submitted with regard to it (referred to as a "statement of change" in this paragraph), there has been no change in the name, or in the address prescribed in paragraph (1), item (i), (a) of that Article, stated in that written application for a tax exemption for book-entry government bonds, written application for a tax exemption for book-entry municipal bonds or statement of change) is deemed to be the written application for a tax exemption referred to in Article 5-2, paragraph (1), item (i) of the New Act on Special Measures Concerning Taxation that was submitted on the Effective Date pursuant to the provisions of that item.

②The provisions of Article 5-2, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to the portion corresponding to the period on or after the Effective Date of the interest on book-entry government bonds prescribed in paragraph (1) of that Article (hereinafter referred to as "book-entry government bonds" in this Article) or book-entry municipal bonds prescribed in that paragraph (hereinafter referred to as "book-entry municipal bonds" in this Article) that a nonresident or foreign corporation that is the trustee of a qualified foreign securities investment trust prescribed in paragraph (2) of that Article receives, and the provisions then in force continue to govern the portion corresponding to the period before the Effective Date of the interest on book-entry government bonds or book-entry municipal bonds that a nonresident or foreign corporation that is the trustee of a qualified foreign securities investment trust prescribed in Article 5-2, paragraph (2) of the Former Act on Special Measures Concerning Taxation receives.

③The approval of the district director obtained before the Effective Date pursuant to the provisions of Article 5-2, paragraph (5), item (iv) of the Former Act on Special Measures Concerning Taxation is deemed, on the Effective Date, to be the approval of the Commissioner of the National Tax Agency obtained pursuant to the provisions of Article 5-2, paragraph (5), item (iv) of the New Act on Special Measures Concerning Taxation.

④The provisions of Article 5-2, paragraphs (9) and (10) of the New Act on Special Measures Concerning Taxation apply to interest received on book-entry government bonds or book-entry municipal bonds for which entries or records under the book-entry transfer system prescribed in paragraph (5), item (vi) of that Article are made in the tax-exempt segregated account prescribed in those provisions, if the first day of the calculation period of that interest is on or after June 1, 2010.

⑤The provisions of Article 5-2, paragraph (15) and paragraphs (19) through (22) of the New Act on Special Measures Concerning Taxation apply to book-entry government bonds or book-entry municipal bonds the first day of the calculation period of whose interest is on or after June 1, 2010, and the provisions then in force continue to govern book-entry government bonds or book-entry municipal bonds the first day of the calculation period of whose interest is before June 1, 2010.

①The provisions of Article 5-3 of the New Act on Special Measures Concerning Taxation apply to interest on specified book-entry corporate bonds, etc. prescribed in paragraph (1) of that Article, the first day of the calculation period of which is on or after June 1, 2010.

②With regard to the application of the provisions of Article 5-3, paragraph (4), items (v) and (vi) of the New Act on Special Measures Concerning Taxation during the period from the Effective Date to May 31, 2010, the phrase "a treaty or any other international agreement concluded by Japan" in item (v) of that paragraph is deemed to be replaced with "a treaty", the phrase "contracting state or contracting party" with "contracting state", and the phrase "treaty partner state, etc." with "treaty partner state", and the phrase "treaty partner state, etc." in item (vi) of that paragraph is deemed to be replaced with "treaty partner state".

①The provisions of Article 6, paragraphs (1) through (3) of the New Act on Special Measures Concerning Taxation apply to interest received on foreign private bonds prescribed in paragraph (1) of that Article that are issued on or after the Effective Date, and the provisions then in force continue to govern interest received on general foreign private bonds prescribed in Article 6, paragraph (1) of the Former Act on Special Measures Concerning Taxation that were issued before the Effective Date.

②The provisions of Article 6, paragraphs (4) through (10) of the New Act on Special Measures Concerning Taxation apply to interest received on foreign private bonds prescribed in paragraph (4) of that Article that are issued on or after the Effective Date, and the provisions then in force continue to govern interest received on general foreign private bonds prescribed in Article 6, paragraph (4) of the Former Act on Special Measures Concerning Taxation that were issued before the Effective Date.

③With regard to interest received on designated private foreign bonds prescribed in Article 6, paragraph (10) of the Former Act on Special Measures Concerning Taxation (referred to as "designated private foreign bonds" in the following paragraph) that were issued before the Effective Date, the provisions then in force continue to govern.

④With regard to interest received on designated private foreign bonds issued during the period from the Effective Date to March 31, 2012, the provisions of Article 6 of the Former Act on Special Measures Concerning Taxation (limited to the part concerning paragraphs (10) through (12)) remain in force. In this case, the phrase "issued by a foreign corporation specified by Cabinet Order as prescribed in paragraph (4)" in paragraph (10) of that Article is deemed to be replaced with "the amount of interest on which is calculated on the basis of an indicator specified by Cabinet Order as prescribed in paragraph (4) of that Article concerning the person issuing those designated private foreign bonds or that issuing person's specially related person (meaning a specially related person prescribed in Article 6, paragraph (4) of the Act on Special Measures Concerning Taxation as amended by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010); the same applies hereinafter in this paragraph)", and the phrase "to interest" is deemed to be replaced with "to interest received by a person other than the issuing person's specially related person".

①The provisions of Article 8-4, paragraph (4) of the New Act on Special Measures Concerning Taxation apply to dividends and similar income on listed shares, etc. prescribed in that paragraph for which the date on which payment was confirmed prescribed in that paragraph falls on or after the Effective Date, and the provisions then in force continue to govern dividends and similar income on listed shares, etc. prescribed in Article 8-4, paragraph (4) of the Former Act on Special Measures Concerning Taxation for which the date on which payment was confirmed prescribed in that paragraph falls before the Effective Date.

②The provisions of Article 8-4, paragraph (5) of the New Act on Special Measures Concerning Taxation apply to dividends and similar income on listed shares, etc. prescribed in paragraph (4) of that Article, or dividends and similar income prescribed in Article 24, paragraph (1) of the New Income Tax Act pertaining to distributions of proceeds from open-end securities investment trusts prescribed in Article 225, paragraph (2), item (i) of the New Income Tax Act, for which the date on which payment was confirmed prescribed in paragraph (5) of that Article falls on or after January 1, 2010, and the provisions then in force continue to govern dividends and similar income on listed shares, etc. prescribed in paragraph (4) of Article 8-4 of the Former Act on Special Measures Concerning Taxation, or dividends and similar income prescribed in Article 24, paragraph (1) of the Former Income Tax Act pertaining to distributions of proceeds from open-end securities investment trusts prescribed in Article 225, paragraph (2), item (i) of the Former Income Tax Act, for which the date on which payment was confirmed prescribed in Article 8-4, paragraph (5) of the Former Act on Special Measures Concerning Taxation falls before January 1 of that year.

The provisions of Article 9-4-2 of the New Act on Special Measures Concerning Taxation apply to the termination or partial cancellation, on or after June 1, 2010, of listed securities investment trusts, etc. prescribed in paragraph (1) of that Article, and the provisions then in force continue to govern the termination or partial cancellation, before that date, of listed securities investment trusts prescribed in Article 9-4-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation.

①With regard to income from the transfer of shares by an individual who, before the Effective Date, transferred shares of a listed company, etc. prescribed in Article 9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation in response to a takeover bid prescribed in that paragraph, the provisions then in force continue to govern.

②Where an individual prescribed in Article 9-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation has, during the period from the Effective Date to December 31, 2010, transferred shares of a listed company, etc. prescribed in that paragraph in response to a takeover bid prescribed in that paragraph, the provisions of that Article remain in force with regard to income from the transfer of those shares. In this case, the phrase "March 31, 2010" in that paragraph is deemed to be replaced with "December 31, 2010", and in paragraph (2) of that Article, the phrase "とあるのは、" (is deemed to be replaced with) is deemed to be replaced with "とあるのは" (is deemed to be replaced with, the reading comma dropped), the phrase "Article 9-6, paragraph (1)" is deemed to be replaced with "Article 9-6, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 51, paragraph (2) of the Supplementary Provisions of that Act", and that paragraph is deemed to further provide that the phrase "that Act" is deemed to be replaced with "the Income Tax Act".

The provisions of Article 9-8 of the New Act on Special Measures Concerning Taxation apply to dividends and similar income on listed shares, etc. in a tax-exempt account prescribed in that Article that are to be received on or after January 1, 2014.

The provisions of Article 10-2-2 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (ii)) apply to equipment for promoting reform of the energy supply and demand structure prescribed in that paragraph that an individual acquires, manufactures or constructs on or after the date specified in Article 1, item (ix) of the Supplementary Provisions, and the provisions then in force continue to govern equipment for promoting reform of the energy supply and demand structure prescribed in Article 10-2-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that an individual acquired, manufactured or constructed before that date.

①The provisions of Article 10-4 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (iv)) apply to machinery and equipment and tools, furniture and fixtures specified in that item that an individual acquires or manufactures on or after the Effective Date, and the provisions then in force continue to govern machinery and equipment and tools, furniture and fixtures specified in Article 10-4, paragraph (1), item (iv) of the Former Act on Special Measures Concerning Taxation that an individual acquired or manufactured before the Effective Date.

②The provisions of Article 10-4 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (v)) apply to depreciable assets specified in that item that an individual acquires or manufactures on or after the Effective Date.

With regard to income tax in the case where an individual has provided information infrastructure enhancement equipment, etc. prescribed in Article 10-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation that the individual acquired or manufactured before the Effective Date for use in a business conducted by the individual prescribed in that paragraph, the provisions of that Article remain in force. In this case, the phrase ", the balance remaining after deducting that amount" in paragraph (4) of that Article is deemed to be replaced with ", the balance remaining after deducting that amount, and in the case where there is an amount to be deducted from the amount of income tax on the amount of gross income for that year pursuant to the provisions of Article 10-4, paragraph (3) (limited to the part concerning paragraph (1), item (v) of that Article) of the Act on Special Measures Concerning Taxation as amended by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), the balance remaining after deducting the amount calculated by multiplying the maximum tax credit prescribed in paragraph (3) of that Article under the provisions of that paragraph by the ratio of the total acquisition cost of the information infrastructure enhancement equipment, etc. prescribed in paragraph (1) of that Article provided for use in that business in that year to the total acquisition cost of the applicable business base strengthening equipment, etc. prescribed in paragraph (4) of that Article provided for use in that business in that year.", and the phrase "and Article 10-6, paragraph (3) of the Act on Special Measures Concerning Taxation" in paragraph (10) of that Article is deemed to be replaced with "and Article 10-6, paragraph (3) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 55 of the Supplementary Provisions of that Act".

①With regard to depreciable assets listed in the third column of item (ii) of the table in Article 11-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that an individual made an acquisition, etc. (meaning acquisition, manufacture or construction; the same applies hereinafter in this Article) of before the Effective Date, the provisions then in force continue to govern.

②With regard to specified telecommunications equipment, etc. prescribed in Article 11-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation that an individual made an acquisition, etc. of before the Effective Date, the provisions then in force continue to govern.

③With regard to resource recycling equipment, etc. prescribed in Article 11-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation that an individual made an acquisition, etc. of before the Effective Date, the provisions then in force continue to govern.

④With regard to the calculation of the number of employees with disabilities prescribed in Article 13, paragraph (5), item (iii) of the Former Act on Special Measures Concerning Taxation in the case where an individual died, or transferred or discontinued the whole of the individual's business, before July 1, 2010, the provisions then in force continue to govern.

⑤With regard to good-quality rental housing in a central urban area prescribed in Article 14, paragraph (1) of the Former Act on Special Measures Concerning Taxation that an individual acquired or newly built before the Effective Date, the provisions of that Article (limited to the part concerning that paragraph) remain in force.

⑥The provisions of Article 14, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to good-quality rental housing for the elderly prescribed in that paragraph that an individual acquires or newly builds on or after the Effective Date, and the provisions then in force continue to govern good-quality rental housing for the elderly prescribed in Article 14, paragraph (2) of the Former Act on Special Measures Concerning Taxation that an individual acquired or newly built before the Effective Date.

①With regard to the economic benefit prescribed in Article 29, paragraph (1) of the Former Act on Special Measures Concerning Taxation that pertains to the period before January 1, 2011, in the case where a salary income earner, etc. prescribed in that paragraph (referred to as a "salary income earner, etc." in this Article) received a loan of funds prescribed in that paragraph without interest or with interest at a low rate, the provisions then in force continue to govern.

②Income tax is not imposed on the economic benefit pertaining to the period on or after January 1, 2011 (where that economic benefit falls under a case specified by Cabinet Order as a case where it significantly exceeds the economic benefit ordinarily received on the basis of the status as an employee, excluding the part equivalent to the amount specified by Cabinet Order as the part of the economic benefit that significantly exceeds it) in the case where a salary income earner, etc., before that date, received from an employer (meaning a person who pays salary, etc. prescribed in Article 28, paragraph (1) of the Income Tax Act or severance pay or other such compensation prescribed in Article 30, paragraph (1) of that Act; the same applies hereinafter in this Article), on the basis of the status as an employee, a loan of funds to be appropriated for the funds required for the acquisition of housing, etc. (meaning land or rights on land, or a house, located in Japan; the same applies hereinafter in this Article) used as the salary income earner, etc.'s own residence, without interest or with interest at a low rate.

③With regard to the amount received prescribed in Article 29, paragraph (2) of the Former Act on Special Measures Concerning Taxation in the case where a salary income earner, etc. received from the employer, on the basis of the status as an employee, an amount equivalent to the whole or part of interest prescribed in paragraph (2) of that Article (referred to as "interest" in the following paragraph) payable before January 1, 2011, to be appropriated for that interest, the provisions then in force continue to govern.

④Where a salary income earner, etc. has, before January 1, 2011, borrowed funds required for the acquisition of housing, etc. used as the salary income earner, etc.'s own residence from a financial institution prescribed in Article 8, paragraph (1) of the New Act on Special Measures Concerning Taxation or any other person specified by Cabinet Order (including the case specified by Cabinet Order where those funds were borrowed from a welfare company prescribed in Article 9, paragraph (3) of the Workers' Property Accumulation Promotion Act (Act No. 92 of 1971)), and has received from the employer, on the basis of the status as an employee, an amount equivalent to the whole or part of interest payable on or after that date, to be appropriated for that interest, income tax is not imposed on the amount received (where that amount falls under a case specified by Cabinet Order as a case where it significantly exceeds the amount ordinarily received on the basis of the status as an employee to be appropriated for that interest, excluding the amount equivalent to the amount specified by Cabinet Order as the amount of the part that significantly exceeds it).

⑤With regard to the portion pertaining to the period before January 1, 2011 of the economic benefit prescribed in Article 29, paragraph (3) of the Former Act on Special Measures Concerning Taxation that a salary income earner, etc. receives through measures necessary to reduce the burden on workers prescribed in Article 9, paragraph (2), item (ii) of the Workers' Property Accumulation Promotion Act or measures equivalent to those measures prescribed in Article 10, paragraph (3) of that Act, or of the amounts received through these measures which are specified by Cabinet Order (referred to as "economic benefit, etc." in this Article), the provisions then in force continue to govern.

⑥Where a salary income earner, etc. has, before January 1, 2011, received a loan of housing funds prescribed in Article 9, paragraph (1) of the Workers' Property Accumulation Promotion Act for the acquisition of housing, etc. used as the salary income earner, etc.'s own residence, income tax is not imposed on the portion of the economic benefit, etc. received by that salary income earner, etc. that pertains to the period on or after that date (excluding the portion to which the provisions of paragraph (2) or (4) apply).

⑦The provisions of paragraphs (2) and (4) and the preceding paragraph do not apply if the economic benefit, the amount received or the economic benefit, etc. prescribed in those provisions is found to have been paid in lieu of salary, etc. prescribed in paragraph (2) or severance pay or other such compensation that is found to have been ordinarily payable to the salary income earner, etc.

①With regard to a transfer of land, etc. prescribed in Article 34-2, paragraph (2), item (vi) of the Former Act on Special Measures Concerning Taxation that an individual made before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 34-2, paragraph (2), item (xxiv) of the New Act on Special Measures Concerning Taxation apply to a transfer, made by an individual on or after the date specified in Article 1, item (x) of the Supplementary Provisions, of land within an area prescribed in item (xxiv) of that paragraph for which the certification under that item was given on or after that date, and the provisions then in force continue to govern a transfer, made by an individual before that date, of land within an area prescribed in Article 34-2, paragraph (2), item (xxiv) of the Former Act on Special Measures Concerning Taxation for which the certification under that item was given before that date.

③The provisions of Article 36-2 of the New Act on Special Measures Concerning Taxation apply to a transfer of transferred assets prescribed in paragraph (1) of that Article made by an individual on or after January 1, 2010, and the provisions then in force continue to govern a transfer of transferred assets prescribed in Article 36-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation made by an individual before that date.

①The provisions of Article 37-10, paragraph (4) of the New Act on Special Measures Concerning Taxation (limited to the part concerning item (i)) apply to the termination or partial cancellation, on or after the Effective Date, of a publicly offered securities investment trust for shares and similar interests, etc. prescribed in that item, and the provisions then in force continue to govern the termination or partial cancellation, before the Effective Date, of a publicly offered securities investment trust for shares and similar interests prescribed in Article 37-10, paragraph (4), item (i) of the Former Act on Special Measures Concerning Taxation.

②The provisions of Article 37-10, paragraph (4) of the New Act on Special Measures Concerning Taxation (limited to the part concerning items (ii) and (iii)) apply to the termination or partial cancellation, on or after January 1, 2010, of a securities investment trust for shares and similar interests, etc. prescribed in item (ii) of that paragraph or a trust split pertaining to a specified trust that issues beneficiary certificates prescribed in item (iii) of that paragraph, and the provisions then in force continue to govern the termination or partial cancellation, before that date, of a securities investment trust for shares and similar interests, etc. prescribed in Article 37-10, paragraph (4), item (ii) of the Former Act on Special Measures Concerning Taxation or a trust split pertaining to a specified trust that issues beneficiary certificates prescribed in item (iii) of that paragraph.

The provisions of Article 37-10-2, paragraph (1) of the New Act on Special Measures Concerning Taxation (excluding the part concerning item (i)) apply to income tax for 2014 and subsequent years, and the provisions then in force continue to govern income tax for 2013 and prior years.

With regard to capital gains from the transfer of listed shares, etc. in the case where an individual made a transfer of listed shares, etc. prescribed in Article 37-11-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation before January 1, 2011, the provisions then in force continue to govern.

With regard to specified shares listed in Article 37-13, paragraph (1), item (iv) of the Former Act on Special Measures Concerning Taxation that an individual acquired by payment before the Effective Date, the provisions then in force continue to govern.

①The provisions of Article 37-14, paragraphs (1) through (5) and paragraphs (14) through (20) of the New Act on Special Measures Concerning Taxation apply to transfers, on or after January 1, 2014, of listed shares, etc. in a tax-exempt account prescribed in paragraph (1) of that Article, and withdrawals, on or after that date, of listed shares, etc. in a tax-exempt account referred to in paragraph (4) of that Article due to the events listed in the items of that paragraph, in relation to a tax-exempt account prescribed in paragraph (5), item (i) of that Article opened on or after January 1, 2014.

②The provisions of Article 37-14, paragraphs (6) through (13) of the New Act on Special Measures Concerning Taxation apply where, on or after January 1, 2014, a person makes a submission of a written notification of opening of a tax-exempt account prescribed in paragraph (5), item (i) of that Article (meaning the submission prescribed in that item; the same applies in the following paragraph) or a submission of the written application referred to in paragraph (6) of that Article (meaning the submission prescribed in that paragraph; the same applies in paragraph (4)).

③A resident or a nonresident who has a permanent establishment in Japan referred to in Article 37-14, paragraph (5), item (i) of the New Act on Special Measures Concerning Taxation who intends to open a tax-exempt account prescribed in that item, and the head of a business office of a financial instruments business operator, etc. prescribed in that item, may, even before January 1, 2014, in accordance with the provisions of that item and paragraphs (11) through (13) of that Article, submit a written notification of opening of a tax-exempt account prescribed in that item, give the notice and conduct the confirmation referred to in paragraph (7) of that Article as applied mutatis mutandis pursuant to paragraph (11) of that Article, provide the matters specified by Order of the Ministry of Finance prescribed in paragraph (13) of that Article (referred to as the "required particulars" in this paragraph), and perform any other necessary acts. In this case, the submission of that written notification of opening of a tax-exempt account, the notice and confirmation, and the provision of the required particulars made in accordance with those provisions are deemed to have been made pursuant to those provisions on that date.

④A resident or a nonresident who has a permanent establishment in Japan referred to in Article 37-14, paragraph (6) of the New Act on Special Measures Concerning Taxation who intends to receive delivery of a written confirmation of opening of a tax-exempt account prescribed in paragraph (5), item (iii) of that Article, the head of a business office of a financial instruments business operator, etc. referred to in paragraph (6) of that Article, and the competent district director prescribed in paragraph (9) of that Article may, even before January 1, 2014, in accordance with the provisions of paragraphs (6) through (10) of that Article, submit the written application referred to in paragraph (6) of that Article, give the notice and conduct the confirmation referred to in paragraph (7) of that Article, provide the application particulars prescribed in paragraph (9) of that Article and enter or record them in books, deliver the written confirmation of opening of a tax-exempt account referred to in paragraph (10), item (i) of that Article or the document referred to in item (ii) of that paragraph, and perform any other necessary acts. In this case, the submission of that written application, the notice and confirmation, the provision of the application particulars and the entry or recording in books, and the delivery of the written confirmation of opening of a tax-exempt account or the document made in accordance with those provisions are deemed to have been made pursuant to those provisions on that date.

The provisions of Article 37-14-2, paragraph (6) of the New Act on Special Measures Concerning Taxation apply where a specified merger, specified company split by split-off or specified share exchange prescribed in paragraphs (1) through (3) of that Article is carried out on or after January 1, 2011, and the provisions then in force continue to govern cases where a specified merger, specified company split by split-off or specified share exchange prescribed in Article 37-14-2, paragraphs (1) through (3) of the Former Act on Special Measures Concerning Taxation was carried out before that date.

The provisions of Article 37-14-3, paragraph (4) of the New Act on Special Measures Concerning Taxation apply where a specified non-qualified merger, specified non-qualified company split by split-off or specified non-qualified share exchange prescribed in paragraphs (1) through (3) of that Article is carried out on or after January 1, 2011, and the provisions then in force continue to govern cases where a specified non-qualified merger, specified non-qualified company split by split-off or specified non-qualified share exchange prescribed in Article 37-14-3, paragraphs (1) through (3) of the Former Act on Special Measures Concerning Taxation was carried out before that date.

The provisions of Article 37-16 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (iv)) apply to income from a transfer of public and corporate bonds prescribed in that item made by an individual on or after the Effective Date.

①The provisions of Article 40-4, paragraphs (1) and (3) of the New Act on Special Measures Concerning Taxation apply to the applicable amount prescribed in paragraph (1) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date and to the taxable amount prescribed in that paragraph pertaining to that applicable amount, and the provisions then in force continue to govern the applicable amount prescribed in Article 40-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date and the taxable amount prescribed in that paragraph pertaining to that applicable amount.

②With regard to the calculation of the applicable amount prescribed in Article 40-4, paragraph (3) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date, the provisions then in force continue to govern.

③The provisions of Article 40-4, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date and to the partially taxable amount prescribed in that paragraph pertaining to that partially applicable amount.

④The provisions of Article 40-4, paragraph (7) of the New Act on Special Measures Concerning Taxation apply where the provisions of paragraph (3) or (5) of that Article are applied to the applicable amount prescribed in paragraph (1) of that Article or the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in paragraph (1) of that Article beginning on or after the Effective Date, and the provisions then in force continue to govern cases where the provisions of Article 40-4, paragraph (3) or (4) of the Former Act on Special Measures Concerning Taxation are applied to the applicable amount prescribed in paragraph (1) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

⑤The provisions of Article 40-5 of the New Act on Special Measures Concerning Taxation apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a resident receives from a foreign corporation on or after the Effective Date, and the provisions then in force continue to govern cases where there is an amount of dividend of surplus, etc. prescribed in Article 40-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a resident received from a specified foreign subsidiary, etc. prescribed in that paragraph before the Effective Date.

⑥The amount of the portion of the taxable retained amount prescribed in Article 40-5, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 5 of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009; referred to as the "2009 Amendment Act" in this paragraph and paragraph (4) of the following Article) (referred to as the "Former Act" in this paragraph and paragraph (4) of the following Article) pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly prescribed in Article 40-5, paragraph (2), item (ii), (a) of the New Act on Special Measures Concerning Taxation (referred to as the "number of shares, etc. held indirectly" in this paragraph) in that specified foreign subsidiary, etc. held by a resident) that corresponds to the year that includes the dividend date prescribed in (a) of that item of that resident, or the amount of the portion of the amount of undeducted dividends, etc. prescribed in Article 40-5, paragraph (2) of the Former Act (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly in that specified foreign subsidiary, etc. held by that resident) that corresponds to each year within the preceding two years prescribed in (b) of that item of that resident, is deemed to be the amount listed in (a) or (b) of that item of that resident, and the provisions of Article 40-5, paragraph (2) of the New Act on Special Measures Concerning Taxation apply. In this case, the amount deemed to be the amount listed in (a) or (b) of that item is not to be included in the amount deemed to be the amount listed in the items of Article 40-5, paragraph (1) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 31, paragraph (3) of the Supplementary Provisions of the 2009 Amendment Act.

①With regard to the calculation of the applicable amount prescribed in Article 40-7, paragraph (3) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 40-7, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign corporation prescribed in that paragraph beginning on or after the Effective Date and to the partially taxable amount prescribed in that paragraph pertaining to that partially applicable amount.

③The provisions of Article 40-8 of the New Act on Special Measures Concerning Taxation apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a resident who is a specially related shareholder, etc. prescribed in that paragraph receives from a foreign corporation on or after the Effective Date, and the provisions then in force continue to govern cases where there is an amount of dividend of surplus, etc. prescribed in Article 40-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a resident who is a specially related shareholder, etc. prescribed in that paragraph received from a specified foreign corporation prescribed in that paragraph before the Effective Date.

④The amount of the portion of the taxable retained amount prescribed in Article 40-11, paragraph (1) of the Former Act pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly prescribed in Article 40-8, paragraph (2), item (ii), (a) of the New Act on Special Measures Concerning Taxation (referred to as the "number of shares, etc. held indirectly" in this paragraph) in that specified foreign corporation held by a resident) that corresponds to the year that includes the dividend date prescribed in (a) of that item of that resident, or the amount of the portion of the amount of undeducted dividends, etc. prescribed in Article 40-11, paragraph (2) of the Former Act (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly in that specified foreign corporation held by that resident) that corresponds to each year within the preceding two years prescribed in (b) of that item of that resident, is deemed to be the amount listed in (a) or (b) of that item of that resident, and the provisions of Article 40-8, paragraph (2) of the New Act on Special Measures Concerning Taxation apply. In this case, the amount deemed to be the amount listed in (a) or (b) of that item is not to be included in the amount deemed to be the amount listed in the items of Article 40-8, paragraph (1) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 32, paragraph (3) of the Supplementary Provisions of the 2009 Amendment Act.

①The provisions of Article 41-13, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to profit from redemption prescribed in paragraph (1) of that Article received on book-entry government bonds prescribed in that paragraph (referred to as "book-entry government bonds" in paragraph (4)) or book-entry municipal bonds prescribed in paragraph (1) of that Article (referred to as "book-entry municipal bonds" in paragraph (4)) acquired on or after the Effective Date.

②The provisions of Article 41-13, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to profit from redemption prescribed in paragraph (2) of that Article received on specified book-entry corporate bonds, etc. prescribed in that paragraph (referred to as "specified book-entry corporate bonds, etc." in paragraph (4)) acquired on or after June 1, 2010.

③The provisions of Article 41-13, paragraph (3) of the New Act on Special Measures Concerning Taxation apply to the issue discount prescribed in paragraph (3) of that Article received on private foreign bonds prescribed in that paragraph (referred to as "private foreign bonds" in the following paragraph) issued on or after the Effective Date, and the provisions then in force continue to govern the issue discount prescribed in Article 41-13 of the Former Act on Special Measures Concerning Taxation received on private foreign bonds prescribed in that Article issued before the Effective Date.

④The provisions of Article 41-13, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to profit from redemption prescribed in paragraph (1) of that Article received on book-entry government bonds or book-entry municipal bonds acquired on or after the Effective Date and the amount of loss arising from their redemption (including retirement by purchase; the same applies hereinafter in this paragraph), profit from redemption prescribed in paragraph (2) of that Article received on specified book-entry corporate bonds, etc. acquired on or after June 1, 2010 and the amount of loss arising from their redemption, and the issue discount prescribed in paragraph (3) of that Article received on private foreign bonds issued on or after the Effective Date and the amount of loss prescribed in paragraph (4) of that Article arising from their redemption.

The provisions of Article 41-16 of the New Act on Special Measures Concerning Taxation apply to income tax for 2011 and subsequent years, and the provisions then in force continue to govern income tax for 2010 and prior years.

The provisions of Article 42-2, paragraph (2), item (i) of the New Act on Special Measures Concerning Taxation apply to specified interest prescribed in paragraph (1) of that Article that a foreign financial institution, etc. prescribed in paragraph (2) of that Article is to receive on or after June 1, 2010, and the provisions then in force continue to govern specified interest prescribed in paragraph (1) of that Article that a foreign financial institution, etc. prescribed in Article 42-2, paragraph (2) of the Former Act on Special Measures Concerning Taxation is to receive before that date.

Except as otherwise provided, the provisions of Chapter III of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation (including an association or foundation without juridical personality prescribed in Article 2, item (viii) of the Corporation Tax Act; the same applies hereinafter) for business years beginning on or after the Effective Date and corporation tax of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation for consolidated business years beginning on or after the Effective Date, and the provisions then in force continue to govern corporation tax of a corporation for business years that began before the Effective Date and corporation tax of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation for consolidated business years that began before the Effective Date.

The provisions of Article 42-4, paragraph (16) of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a distribution in kind (meaning a distribution in kind prescribed in Article 10, paragraph (2) of the Supplementary Provisions; the same applies hereinafter) is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a post-formation acquisition of assets (meaning a post-formation acquisition of assets prescribed in Article 10, paragraph (2) of the Supplementary Provisions; the same applies hereinafter up to Article 122 of the Supplementary Provisions) was carried out before that date.

The provisions of Article 42-5 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (ii)) apply to equipment, etc. for promoting reform of the energy supply and demand structure prescribed in that paragraph that a corporation acquires, manufactures or constructs on or after the date specified in Article 1, item (ix) of the Supplementary Provisions, and the provisions then in force continue to govern equipment, etc. for promoting reform of the energy supply and demand structure prescribed in Article 42-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired, manufactured or constructed before that date.

①The provisions of Article 42-7 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (iv)) apply to machinery and equipment and tools, furniture and fixtures specified in that item that a corporation acquires or manufactures on or after the Effective Date, and the provisions then in force continue to govern machinery and equipment and tools, furniture and fixtures specified in Article 42-7, paragraph (1), item (iv) of the Former Act on Special Measures Concerning Taxation that a corporation acquired or manufactured before the Effective Date.

②The provisions of Article 42-7 of the New Act on Special Measures Concerning Taxation (limited to the part concerning paragraph (1), item (v)) apply to depreciable assets specified in that item that a corporation acquires or manufactures on or after the Effective Date.

①With regard to depreciable assets listed in the third column of item (ii) of the table in Article 44, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation made an acquisition, etc. (meaning acquisition, manufacture or construction; the same applies hereinafter in this Article) of before the Effective Date, the provisions then in force continue to govern.

②With regard to specified telecommunications equipment, etc. prescribed in Article 44-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation made an acquisition, etc. of before the Effective Date, the provisions then in force continue to govern.

③With regard to resource recycling equipment, etc. prescribed in Article 44-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation made an acquisition, etc. of before the Effective Date, the provisions then in force continue to govern.

④The provisions of Article 46-2, paragraph (3), item (iii) of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years ending on or after July 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years that ended before that date.

⑤With regard to good-quality rental housing in a central urban area prescribed in Article 47, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired or newly built before the Effective Date, the provisions of that Article (limited to the part concerning that paragraph) remain in force. In this case, the phrase "Article 68-34, paragraph (1)" in paragraph (2) of that Article is deemed to be replaced with "Article 68-34, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 112, paragraph (5) of the Supplementary Provisions of that Act".

⑥With regard to the application of the provisions of the preceding paragraph and of Article 47 of the Former Act on Special Measures Concerning Taxation which remains in force pursuant to the provisions of that paragraph in the case where a merger, company split, capital contribution in kind or distribution in kind is carried out on or after October 1, 2010, the phrase "in paragraph (2) of that Article" in that paragraph is deemed to be replaced with "in paragraph (2) of that Article, the phrase 'qualified post-formation acquisition of assets' is deemed to be replaced with 'qualified in-kind distribution (hereinafter referred to as a "qualified merger, etc." in this paragraph)', the phrase 'qualified merger, qualified company split or qualified capital contribution in kind (hereinafter referred to as a "qualified merger, etc." in this paragraph)' with 'qualified merger, etc.', the phrase 'or a corporation making a capital contribution in kind' with ', a corporation making a capital contribution in kind or a corporation making a distribution in kind', and the phrase 'or a qualified company split by split-off, the day before the date of the qualified merger or qualified company split by split-off' with ', the day before the date of the qualified merger, and for a qualified in-kind distribution that falls under a distribution of all of the residual assets, the date of determination of the residual assets pertaining to that qualified in-kind distribution.', and", and the phrase "とあるのは、" (is deemed to be replaced with, followed by a comma) is deemed to be replaced with "とあるのは" (is deemed to be replaced with, without a comma).

⑦The provisions of Article 47, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to good-quality rental housing for the elderly prescribed in that paragraph that a corporation acquires or newly builds on or after the Effective Date, and the provisions then in force continue to govern good-quality rental housing for the elderly prescribed in Article 47, paragraph (3) of the Former Act on Special Measures Concerning Taxation that a corporation acquired or newly built before the Effective Date.

⑧The provisions of Article 47, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to good-quality rental housing for the elderly prescribed in that paragraph that a corporation receives as a transfer through a qualified company split or qualified in-kind distribution prescribed in that paragraph carried out on or after October 1, 2010.

⑨With regard to good-quality rental housing for the elderly prescribed in Article 47, paragraph (4) of the Former Act on Special Measures Concerning Taxation that a corporation received as a transfer through a qualified company split or qualified post-formation acquisition of assets prescribed in that paragraph carried out before October 1, 2010, the provisions of that Article (limited to the part concerning that paragraph) remain in force. In this case, the phrase "Article 68-34, paragraph (3)" in that paragraph is deemed to be replaced with "Article 68-34, paragraph (3) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 112, paragraph (9) of the Supplementary Provisions of that Act".

⑩The provisions of Article 47-2, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to specified redevelopment buildings, etc. prescribed in that paragraph that a corporation receives as a transfer through a qualified company split or qualified in-kind distribution prescribed in that paragraph carried out on or after October 1, 2010.

⑪With regard to specified redevelopment buildings, etc. prescribed in Article 47-2, paragraph (2) of the Former Act on Special Measures Concerning Taxation that a corporation received as a transfer through a qualified company split or qualified post-formation acquisition of assets prescribed in that paragraph carried out before October 1, 2010, the provisions of that Article (limited to the part concerning that paragraph) remain in force. In this case, the phrase "Article 68-35, paragraph (1)" in that paragraph is deemed to be replaced with "Article 68-35, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 112, paragraph (11) of the Supplementary Provisions of that Act".

⑫The provisions of Article 48, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to warehouse buildings, etc. prescribed in that paragraph that a corporation receives as a transfer through a qualified company split or qualified in-kind distribution prescribed in that paragraph carried out on or after October 1, 2010.

⑬With regard to warehouse buildings, etc. prescribed in Article 48, paragraph (2) of the Former Act on Special Measures Concerning Taxation that a corporation received as a transfer through a qualified company split or qualified post-formation acquisition of assets prescribed in that paragraph carried out before October 1, 2010, the provisions of that Article (limited to the part concerning that paragraph) remain in force. In this case, the phrase "Article 68-36, paragraph (1)" in that paragraph is deemed to be replaced with "Article 68-36, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 18 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2010), which remains in force pursuant to the provisions of Article 112, paragraph (13) of the Supplementary Provisions of that Act".

The provisions of Article 52-2, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to assets subject to special depreciation prescribed in paragraph (4) of that Article that a corporation receives as a transfer through a qualified company split or qualified in-kind distribution prescribed in that paragraph carried out on or after October 1, 2010, and the provisions then in force continue to govern assets subject to special depreciation prescribed in Article 52-2, paragraph (4) of the Former Act on Special Measures Concerning Taxation that a corporation received as a transfer through a qualified company split or qualified post-formation acquisition of assets prescribed in that paragraph carried out before that date.

The provisions of Article 52-3 of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a company split or distribution in kind is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a company split or post-formation acquisition of assets was carried out before that date.

①The provisions of Article 55 (excluding the part concerning items (iii) and (iv) of the table in paragraph (1), paragraph (2), item (i) and paragraph (9)), Articles 55-5 through 56, Article 57-5, Article 57-6, Article 57-8, Article 57-9 and Article 58 of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a company split or distribution in kind is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a company split or post-formation acquisition of assets was carried out before that date.

②The provisions of Article 55 of the New Act on Special Measures Concerning Taxation (limited to the part concerning items (iii) and (iv) of the table in paragraph (1) and paragraph (2), item (i)) apply to specified shares, etc. prescribed in paragraph (1) of that Article that a corporation acquires on or after the Effective Date, and the provisions then in force continue to govern specified shares, etc. prescribed in Article 55, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired before the Effective Date.

③The provisions of Article 55, paragraph (9) of the New Act on Special Measures Concerning Taxation (limited to the part concerning the ratio by which the acquisition cost of specified shares, etc. prescribed in that paragraph is multiplied) apply to those specified shares, etc. that a corporation acquires on or after the Effective Date, and the provisions then in force continue to govern specified shares, etc. prescribed in Article 55, paragraph (9) of the Former Act on Special Measures Concerning Taxation that a corporation acquired before the Effective Date.

④The provisions of Article 55, paragraph (9) of the New Act on Special Measures Concerning Taxation (excluding the part concerning the ratio by which the acquisition cost of specified shares, etc. prescribed in that paragraph is multiplied) apply to corporation tax of a corporation for business years in the case where a qualified company split or qualified in-kind distribution prescribed in that paragraph is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a qualified company split by spin-off or qualified post-formation acquisition of assets prescribed in Article 55, paragraph (9) of the Former Act on Special Measures Concerning Taxation was carried out before that date.

The provisions of Article 57-10, paragraph (2) of the New Act on Special Measures Concerning Taxation apply to a qualified company split, etc. prescribed in that paragraph that a corporation carries out on or after October 1, 2010.

①With regard to corporation tax for business years ending on or after the Effective Date of a corporation prescribed in Article 61-2, paragraph (1) and Article 61-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation (limited to a certified agricultural production corporation, etc. prescribed in Article 61-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that is listed in Article 2, paragraph (2), item (i), (b) of the Act on Payment of Grants to Farmers for Purpose of Stabilization of Farming Management (Act No. 88 of 2006) prescribed in that paragraph) that holds an amount of reserve for strengthening the farm management base prescribed in Article 61-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that it accumulated before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 61-3, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to agricultural land prescribed in that paragraph that a corporation acquires through a qualified in-kind distribution prescribed in that paragraph carried out on or after October 1, 2010, and the provisions then in force continue to govern agricultural land prescribed in Article 61-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired through a qualified post-formation acquisition of assets prescribed in that paragraph carried out before that date.

With regard to the application of the provisions of Article 61-4, paragraph (1) of the New Act on Special Measures Concerning Taxation to corporation tax of a corporation for business years in the case where a dissolution takes place during the period from the Effective Date to September 30, 2010, the phrase "each business year" in that paragraph is deemed to be replaced with "each business year (excluding each business year during liquidation)".

The provisions of Article 62, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a dissolution takes place on or after October 1, 2010, and the provisions then in force continue to govern corporation tax on liquidation income prescribed in Article 62, paragraph (1) of the Former Act on Special Measures Concerning Taxation of a corporation in the case where a dissolution prescribed in that paragraph took place before that date.

①The provisions of Articles 64 through 65, Article 65-3 (limited to the part concerning paragraph (3), item (iv)), Article 65-4 (limited to the part concerning paragraph (3), item (iv)), Article 65-5-2, Article 65-7, Article 65-8 and Articles 65-10 through 66-2 of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a company split or distribution in kind is carried out on or after October 1, 2010 or a dissolution takes place on or after that date, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a company split or post-formation acquisition of assets was carried out before that date or a dissolution took place before that date.

②With regard to corporation tax pertaining to a transfer of land, etc. prescribed in Article 65-4, paragraph (1), item (vi) of the Former Act on Special Measures Concerning Taxation that a corporation made before the Effective Date, the provisions then in force continue to govern.

③The provisions of Article 65-4, paragraph (1), item (xxiv) of the New Act on Special Measures Concerning Taxation apply to corporation tax pertaining to a transfer, made by a corporation on or after the date specified in Article 1, item (x) of the Supplementary Provisions, of land within an area prescribed in item (xxiv) of that paragraph for which the certification under that item was given on or after that date, and the provisions then in force continue to govern corporation tax pertaining to a transfer, made by a corporation before that date, of land within an area prescribed in Article 65-4, paragraph (1), item (xxiv) of the Former Act on Special Measures Concerning Taxation for which the certification under that item was given before that date.

①With regard to corporation tax on liquidation income prescribed in Article 66-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation of a corporation prescribed in that paragraph in the case where the dissolution of that corporation (excluding dissolution due to a merger) took place on or before September 30, 2010, the provisions then in force continue to govern.

②With regard to corporation tax on income for business years during liquidation of a corporation prescribed in Article 66-4, paragraph (3) of the Former Act on Special Measures Concerning Taxation in the case where the dissolution of that corporation (excluding dissolution due to a merger) took place on or before September 30, 2010, the provisions then in force continue to govern.

③With regard to the application of the provisions of Article 66-4, paragraph (8) of the Former Act on Special Measures Concerning Taxation during the period from the Effective Date to September 30, 2010, the phrase "books and documents retained" in that paragraph is deemed to be replaced with "books and documents retained (including, where electromagnetic records have been created or retained in lieu of the creation or retention of those books and documents, those electromagnetic records; the same applies hereinafter in this paragraph, the following paragraph and paragraph (12), item (ii))".

With regard to corporation tax on liquidation income of a domestic corporation prescribed in Article 66-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation (including corporation tax on income for business years during liquidation of a corporation subject to corporation tax on liquidation income) in the case where the dissolution of that domestic corporation (excluding dissolution due to a merger) took place on or before September 30, 2010, the provisions then in force continue to govern.

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

②With regard to the calculation of the applicable amount prescribed in Article 66-6, paragraph (3) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date, the provisions then in force continue to govern.

③The provisions of Article 66-6, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date and to the partially taxable amount prescribed in that paragraph pertaining to that partially applicable amount.

④The provisions of Article 66-6, paragraph (7) of the New Act on Special Measures Concerning Taxation apply where the provisions of paragraph (3) or (5) of that Article are applied to the applicable amount prescribed in paragraph (1) of that Article or the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in paragraph (1) of that Article beginning on or after the Effective Date, and the provisions then in force continue to govern cases where the provisions of Article 66-6, paragraph (3) or (4) of the Former Act on Special Measures Concerning Taxation are applied to the applicable amount prescribed in paragraph (1) of that Article pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

⑤The provisions of Article 66-7 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 or the partially taxable amount prescribed in that paragraph pertaining to business years of a specified foreign subsidiary, etc. 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 66-7, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to the taxable amount prescribed in that paragraph pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

⑥The provisions of Article 66-8 of the New Act on Special Measures Concerning Taxation (excluding paragraphs (3), (6), (7) and (10)) apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a domestic corporation receives from a foreign corporation in a business year beginning on or after the Effective Date, and the provisions then in force continue to govern cases where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of Article 66-8 of the Former Act on Special Measures Concerning Taxation that a domestic corporation received from a specified foreign subsidiary, etc. prescribed in paragraph (2) of that Article in a business year that began before the Effective Date.

⑦The provisions of Article 66-8, paragraphs (3) and (10) of the New Act on Special Measures Concerning Taxation apply to the amount of dividend of surplus, etc. prescribed in paragraph (3) of that Article pertaining to shares or capital contributions that a domestic corporation acquires (including succession through a qualified merger or qualified company split by split-off) on or after October 1, 2010.

⑧The provisions of Article 66-8, paragraphs (6) and (7) of the New Act on Special Measures Concerning Taxation apply to the taxed amount for each business year within the preceding ten years of a domestic corporation prescribed in paragraph (6) of that Article and the taxed amount for each business year within ten years before the company split, etc. of a split corporation, etc. prescribed in paragraph (7) of that Article in the case where, on or after October 1, 2010, a qualified company split by split-off or a qualified in-kind distribution (where the qualified in-kind distribution is a distribution of residual assets, limited to one resulting from a dissolution on or after that date) is carried out, and the provisions then in force continue to govern the taxed amount for each business year within the preceding ten years of a domestic corporation prescribed in Article 66-8, paragraph (6) of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 18 (limited to the amending provisions listed in Article 1, item (iii), (i) of the Supplementary Provisions) and the taxed amount for each business year within ten years before the company split or each business year within ten years before the company split, etc. of a split corporation, etc. prescribed in paragraph (7) of that Article in the case where a qualified company split by split-off or a qualified post-formation acquisition of assets was carried out before that date. In this case, with regard to the application of the provisions of paragraph (6), item (ii) of that Article in the case where a qualified company split by split-off is carried out during the period from the Effective Date to September 30, 2010, the phrase "specified foreign subsidiary, etc." in that item is deemed to be replaced with "foreign corporation".

⑨The amount of the portion of the taxable retained amount prescribed in Article 66-8, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by Article 5 of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009; referred to as the "2009 Amendment Act" in this paragraph and paragraph (7) of the following Article) (referred to as the "Former Act" in this paragraph and paragraph (7) of the following Article) pertaining to business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly prescribed in Article 66-8, paragraph (11), item (ii), (a) of the New Act on Special Measures Concerning Taxation (referred to as the "number of shares, etc. held indirectly" in this paragraph) in that specified foreign subsidiary, etc. held by a domestic corporation; the same applies hereinafter in this paragraph) that corresponds to the dividend business year prescribed in (a) of that item (referred to as the "dividend business year" in this paragraph) of that domestic corporation, or the amount of the portion of the taxed retained amount prescribed in Article 66-8, paragraph (1) of the Former Act (including an amount deemed to be the taxed retained amount prescribed in paragraph (1) of that Article pursuant to the provisions of paragraph (2) or (3) of that Article, and limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly in that specified foreign subsidiary, etc. held by that domestic corporation; the same applies hereinafter in this paragraph) that corresponds to each business year within the preceding two years prescribed in (b) of that item (referred to as "each business year within the preceding two years" in this paragraph) of that domestic corporation (excluding the amount equivalent to the amount of dividend of surplus, etc. prescribed in (b) of that item that is deducted pursuant to the provisions of (b) of that item), is deemed to be the amount listed in (a) or (b) of that item for the dividend business year or each business year within the preceding two years corresponding to the period of the business year or consolidated business year pertaining to the taxable retained amount or taxed retained amount of that domestic corporation, and the provisions of Article 66-8, paragraphs (8) through (11) of the New Act on Special Measures Concerning Taxation apply. In this case, the amount deemed to be the amount listed in (a) or (b) of that item is not to be included in the amount deemed to be the amount listed in the items of Article 66-8, paragraph (3) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 44, paragraph (4) of the Supplementary Provisions of the 2009 Amendment Act.

⑩With regard to the application of the provisions of Article 66-8, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a merger is carried out during the period from the Effective Date to September 30, 2010, the phrase "business year within ten years before the merger, etc." in the row for paragraph (6), item (i) of the table in that paragraph is deemed to be replaced with "business year within ten years before the merger", and the phrase "business year within two years before the merger, etc." is deemed to be replaced with "business year within two years before the merger".

⑪With regard to the application of the provisions of Article 66-8, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a company split by split-off is carried out during the period from the Effective Date to September 30, 2010, in the row for paragraph (6), item (ii) of the table in that paragraph, the phrase "business year within ten years before the company split, etc." is deemed to be replaced with "business year within ten years before the company split", the phrase "business year within two years before the company split, etc." with "business year within two years before the company split", the phrase "number of shares, etc. held directly" with "number of shares, etc. held directly pertaining to the specified foreign subsidiary, etc.", and the phrase "number of shares, etc. held indirectly" with "number of shares, etc. held indirectly pertaining to the foreign corporation", and in the row for paragraph (7) of that table, the phrase "business year within ten years before the company split, etc." is deemed to be replaced with "business year within ten years before the company split or business year within ten years before the company split, etc.", and the phrase "business year within two years before the company split, etc." with "business year within two years before the company split".

⑫With regard to the application of the provisions of Article 66-8, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a company split by spin-off, capital contribution in kind or post-formation acquisition of assets is carried out during the period from the Effective Date to September 30, 2010, the phrase "paragraph (6), item (ii)" in the row for paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "paragraph (6), item (iii)".

①With regard to the calculation of the applicable amount prescribed in Article 66-9-2, paragraph (3) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 66-9-2, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to the partially applicable amount prescribed in paragraph (4) of that Article pertaining to business years of a specified foreign corporation prescribed in that paragraph beginning on or after the Effective Date and to the partially taxable amount prescribed in that paragraph pertaining to that partially applicable amount.

③The provisions of Article 66-9-3 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 or the partially taxable amount prescribed in that paragraph pertaining to 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 66-9-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to the taxable amount prescribed in that paragraph pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date.

④The provisions of Article 66-9-4 of the New Act on Special Measures Concerning Taxation (excluding paragraphs (3) and (9)) apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a domestic corporation that is a specially related shareholder, etc. prescribed in that paragraph receives from a foreign corporation in a business year beginning on or after the Effective Date, and the provisions then in force continue to govern cases where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of Article 66-9-4 of the Former Act on Special Measures Concerning Taxation that a domestic corporation that is a specially related shareholder, etc. prescribed in paragraph (2) of that Article received from a specified foreign corporation prescribed in that paragraph in a business year that began before the Effective Date.

⑤The provisions of Article 66-9-4, paragraphs (3) and (9) of the New Act on Special Measures Concerning Taxation apply to the amount of dividend of surplus, etc. prescribed in paragraph (3) of that Article pertaining to shares or capital contributions that a domestic corporation acquires (including succession through a qualified merger or qualified company split by split-off) on or after October 1, 2010.

⑥With regard to the application of the provisions of Article 66-9-4, paragraph (6) of the New Act on Special Measures Concerning Taxation in the case where a company split by spin-off, capital contribution in kind or post-formation acquisition of assets is carried out during the period from the Effective Date to September 30, 2010, the phrase "Article 66-8, paragraph (6), item (ii)" in the row for Article 66-8, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 66-8, paragraph (6), items (ii) and (iii)".

⑦The amount of the portion of the taxable retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly prescribed in Article 66-9-4, paragraph (10), item (ii), (a) of the New Act on Special Measures Concerning Taxation (referred to as the "number of shares, etc. held indirectly" in this paragraph) in that specified foreign corporation held by a domestic corporation; the same applies hereinafter in this paragraph) that corresponds to the dividend business year prescribed in (a) of that item (referred to as the "dividend business year" in this paragraph) of that domestic corporation, or the amount of the portion of the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act (including an amount deemed, pursuant to the provisions of Article 66-8, paragraph (3) of the Former Act as applied with the replacement of terms pursuant to paragraph (2) or (3) of Article 66-9-8 of the Former Act, to be the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act, and limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly in that specified foreign corporation held by that domestic corporation; the same applies hereinafter in this paragraph) that corresponds to each business year within the preceding two years prescribed in (b) of that item (referred to as "each business year within the preceding two years" in this paragraph) of that domestic corporation (excluding the amount equivalent to the amount of dividend of surplus, etc. prescribed in (b) of that item that is deducted pursuant to the provisions of (b) of that item), is deemed to be the amount listed in (a) or (b) of that item for the dividend business year or each business year within the preceding two years corresponding to the period of the business year or consolidated business year pertaining to the taxable retained amount or taxed retained amount of that domestic corporation, and the provisions of Article 66-9-4, paragraphs (7) through (10) of the New Act on Special Measures Concerning Taxation apply. In this case, the amount deemed to be the amount listed in (a) or (b) of that item is not to be included in the amount deemed to be the amount listed in the items of Article 66-9-4, paragraph (3) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 45, paragraph (4) of the Supplementary Provisions of the 2009 Amendment Act.

⑧With regard to the application of the provisions of Article 66-9-4, paragraph (12) of the New Act on Special Measures Concerning Taxation in the case where a merger is carried out during the period from the Effective Date to September 30, 2010, the phrase "business year within ten years before the merger, etc." in the row for Article 66-8, paragraph (6), item (i) of the table in that paragraph is deemed to be replaced with "business year within ten years before the merger", and the phrase "business year within two years before the merger, etc." is deemed to be replaced with "business year within two years before the merger".

⑨With regard to the application of the provisions of Article 66-9-4, paragraph (12) of the New Act on Special Measures Concerning Taxation in the case where a company split by split-off is carried out during the period from the Effective Date to September 30, 2010, in the row for Article 66-8, paragraph (6), item (ii) of the table in that paragraph, the phrase "business year within ten years before the company split, etc." is deemed to be replaced with "business year within ten years before the company split", the phrase "business year within two years before the company split, etc." with "business year within two years before the company split", the phrase "number of shares, etc. held directly" with "number of shares, etc. held directly pertaining to the specified foreign subsidiary, etc.", and the phrase "number of shares, etc. held indirectly" with "number of shares, etc. held indirectly pertaining to the foreign corporation", and in the row for Article 66-8, paragraph (7) of that table, the phrase "business year within ten years before the company split, etc." is deemed to be replaced with "business year within ten years before the company split or business year within ten years before the company split, etc.", and the phrase "business year within two years before the company split, etc." with "business year within two years before the company split".

⑩With regard to the application of the provisions of Article 66-9-4, paragraph (12) of the New Act on Special Measures Concerning Taxation in the case where a company split by spin-off, capital contribution in kind or post-formation acquisition of assets is carried out during the period from the Effective Date to September 30, 2010, the phrase "Article 66-8, paragraph (6), item (ii)" in the row for Article 66-8, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 66-8, paragraph (6), item (iii)".

With regard to donations prescribed in Article 66-12, paragraph (1) of the Former Act on Special Measures Concerning Taxation to a specified regional employment company prescribed in that paragraph that a corporation makes within the period of validity of a designation prescribed in that paragraph that was made before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 66-13, paragraph (1) of the New Act on Special Measures Concerning Taxation (excluding the part concerning item (i)) apply to corporation tax of a corporation for business years in the case where a dissolution takes place on or after October 1, 2010, and the provisions then in force continue to govern corporation tax pertaining to business years during liquidation of a corporation in the case where a dissolution took place before that date.

The provisions of Article 67-4 of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a company split or distribution in kind is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a company split or post-formation acquisition of assets was carried out before that date.

The provisions of Article 67-6, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to distributions of proceeds of a specified stock investment trust prescribed in that paragraph received by a corporation that is dissolved on or after October 1, 2010, and the provisions then in force continue to govern distributions of proceeds of a specified stock investment trust prescribed in Article 67-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation received by a corporation that was dissolved before that date.

①The provisions of Article 67-14, paragraph (1), item (i), (b), 2. and (c) (limited to the part concerning base specified equity prescribed in (c) of that item) of the New Act on Special Measures Concerning Taxation apply to corporation tax of a specific purpose company prescribed in that paragraph (referred to as a "specific purpose company" in this paragraph) for business years beginning on or after the Effective Date (for a specific purpose company established before the Effective Date that did not file the notification of commencement of business prescribed in Article 4, paragraph (2) of the Act on the Securitization of Assets (Act No. 105 of 1998) by March 31, 2015 (referred to as a "company yet to file its notification" in this paragraph), limited to business years ending on or after April 1, 2015, and for a specific purpose company established before the Effective Date (excluding a company yet to file its notification), limited to business years ending on or after the day on which it first files a notification of change, etc. (meaning a notification of a change in the matters listed in Article 5, paragraph (1), item (i) of the Act on the Securitization of Assets under the provisions of Article 9, paragraph (1) of that Act, or a notification under the provisions of Article 10, paragraph (1) of that Act, pertaining to the asset securitization plan prescribed in Article 67-14, paragraph (1), item (i), (c) of the New Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) on or after the Effective Date), and the provisions then in force continue to govern corporation tax of a specific purpose company for business years that began before the Effective Date (including, for a company yet to file its notification, business years that began on or after the Effective Date and ended before April 1, 2015, and, for a specific purpose company established before the Effective Date (excluding a company yet to file its notification), business years that began on or after the Effective Date and ended before the day on which it first files a notification of change, etc. on or after the Effective Date). In this case, with regard to the application of the provisions of Article 67-14, paragraph (1), item (i), (b), 2. of the New Act on Special Measures Concerning Taxation to business years of a company yet to file its notification ending before the day on which it first files a notification of change, etc., the phrase "expected to be held" in (b), 2. of that item is deemed to be replaced with "subscribed for".

②The provisions of Article 67-14, paragraph (1), item (i), (c) of the New Act on Special Measures Concerning Taxation (excluding the part concerning base specified equity prescribed in (c) of that item) apply to corporation tax of a specific purpose company prescribed in that paragraph for business years ending on or after the Effective Date, and the provisions then in force continue to govern corporation tax of a specific purpose company prescribed in Article 67-14, paragraph (1) of the Former Act on Special Measures Concerning Taxation for business years that ended before the Effective Date.

③The provisions of Article 67-14, paragraph (6) of the New Act on Special Measures Concerning Taxation apply to the amount of dividends of profits prescribed in that paragraph received by a corporation that is dissolved on or after October 1, 2010, and the provisions then in force continue to govern the amount of dividends of profits prescribed in Article 67-14, paragraph (6) of the Former Act on Special Measures Concerning Taxation received by a corporation that was dissolved before that date.