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 dividends of surplus and similar distributions 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 dividends of surplus and similar distributions 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 dividends of surplus and similar distributions 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 dividends of surplus and similar distributions 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.