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)".