①Where a corporation has had the approval under Article 4-2 of the Former Corporation Tax Act revoked pursuant to the provisions of Article 4-5, paragraph (1) or (2) of the Former Corporation Tax Act (including the case where it has had the approval under Article 4-2 of the Former Corporation Tax Act revoked as remaining governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (1) or (2) of the Supplementary Provisions; referred to as the "case of revocation of approval" in this paragraph), has obtained the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has obtained the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as remaining governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions; referred to as the "case of approval of withdrawal" in this paragraph), or has received the application of the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions (referred to as the "case where consolidated tax payment ends" in this paragraph), if there is an individually attributed consolidated excess interest amount (meaning an individually attributed consolidated excess interest amount prescribed in Article 68-89-3, paragraph (6) of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter in this Article) of the corporation that arose in each consolidated business year that began within seven years before the first day of the business year that includes the day following the end of the last consolidated business year in that case of revocation of approval, that case of approval of withdrawal or that case where consolidated tax payment ends, then, with regard to the application of the provisions of Article 66-5-3, paragraphs (1) and (2) of the Act on Special Measures Concerning Taxation as Amended for 2022, that individually attributed consolidated excess interest amount is deemed to be an excess interest amount (meaning an excess interest amount prescribed in Article 66-5-3, paragraph (1) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this Article) that arose in the business year of the corporation that includes the first day of the consolidated business year in which that individually attributed consolidated excess interest amount arose (or, if the provisions of Article 29, paragraph (1) of the Supplementary Provisions have been applied, the end of that consolidated business year).

②Where the merged corporation pertaining to the qualified merger referred to in Article 66-5-3, paragraph (3) of the Act on Special Measures Concerning Taxation as Amended for 2022 is a consolidated corporation (meaning a consolidated corporation prescribed in Article 2, paragraph (2), item (x)-6 of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter in this paragraph and the following paragraph) (for a consolidated subsidiary corporation, limited to one that carries out, on the day following the end of the consolidated business year, a qualified merger in which that consolidated subsidiary corporation is the merged corporation), or where the other corporation whose residual assets have been determined as referred to in Article 66-5-3, paragraph (3) of the Act on Special Measures Concerning Taxation as Amended for 2022 is a consolidated corporation (limited to a consolidated subsidiary corporation whose residual assets were determined at the end of the consolidated business year of that consolidated corporation), the provisions of that paragraph apply by deeming the individually attributed consolidated excess interest amount that arose in each consolidated business year of that merged corporation or other corporation that began within seven years before the date of that qualified merger, or that began within seven years before the day following the date of determination of those residual assets, to be an excess interest amount that arose in a business year within the preceding seven years prescribed in that paragraph, a consolidated tax return to be a final return, and the consolidated business year in which that individually attributed consolidated excess interest amount arose to be a business year of that merged corporation or other corporation, respectively.

③In the case prescribed in the preceding paragraph, if the consolidated corporation that is the merged corporation pertaining to the qualified merger referred to in that paragraph or the other corporation whose residual assets have been determined has an excess interest amount that arose in a business year, among the business years preceding each consolidated business year prescribed in that paragraph, that falls under the category of a business year within the preceding seven years prescribed in Article 66-5-3, paragraph (3) of the Act on Special Measures Concerning Taxation as Amended for 2022, the provisions of that paragraph do not apply to that excess interest amount.

④With regard to the application of the provisions of Article 66-5-3, paragraphs (1) and (2) of the Act on Special Measures Concerning Taxation as Amended for 2022 in each business year after the last consolidated business year in the case where the corporation referred to in Article 66-5-3, paragraph (1) or (2) of the Act on Special Measures Concerning Taxation as Amended for 2022 has had the approval under Article 4-2 of the Former Corporation Tax Act revoked pursuant to the provisions of Article 4-5, paragraph (1) or (2) of the Former Corporation Tax Act after the end of the first consolidated business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act (including the case where it has had the approval under Article 4-2 of the Former Corporation Tax Act revoked as remaining governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (1) or (2) of the Supplementary Provisions), the case where it has obtained the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has obtained the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as remaining governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions), or the case where it has received the application of the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions, the excess interest amount that arose in each business year preceding that consolidated business year (including an amount deemed, in that business year, to be an excess interest amount that arose in a business year preceding that business year pursuant to the provisions of Article 66-5-3, paragraph (3) or (4) of the Act on Special Measures Concerning Taxation Before the 2022 Changes) is deemed not to exist.

⑤With regard to the application of the provisions of Article 66-5-3, paragraph (3) of the Act on Special Measures Concerning Taxation as Amended for 2022 in the case where the provisions of paragraph (1) or the preceding paragraph apply, the phrase "of this paragraph" in that paragraph is deemed to be replaced with "of this paragraph or Article 125, paragraph (1) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020)", the phrase "including" with "including, but excluding an amount deemed not to exist pursuant to the provisions of paragraph (4) of that Article,", and the phrase "item (xxxi) of that Article" with "Article 2, item (xxxi) of the Corporation Tax Act".

⑥With regard to an amount deemed to be an excess interest amount of a corporation pursuant to the provisions of paragraph (1), or an amount deemed to be an excess interest amount of a corporation pursuant to the provisions of Article 66-5-3, paragraph (3) of the Act on Special Measures Concerning Taxation as Amended for 2022 as applied by the deeming under paragraph (2), the provisions of paragraphs (1) and (2) of that Article apply only if those corporations have filed a final return for the business year that includes the day following the end of the last consolidated business year referred to in paragraph (1), or for each business year on or after the business year of merger, etc. prescribed in paragraph (3) of that Article as applied by the deeming under paragraph (2), and a document stating the matters prescribed in Article 66-5-3, paragraph (4) of the Act on Special Measures Concerning Taxation as Amended for 2022 is attached to the tax return, etc. prescribed in Article 2, paragraph (2), item (xxviii) of the Act on Special Measures Concerning Taxation as Amended for 2022, the amended return prescribed in item (xxxi) of that paragraph or the written request for reassessment prescribed in item (xxxii) of that paragraph, for the business year for which the corporation seeks to receive the application of the provisions of Article 66-5-3, paragraphs (1) and (2) of the Act on Special Measures Concerning Taxation as Amended for 2022. In this case, the excess interest amount that serves as the basis for calculating the amount to be included in deductible expenses pursuant to the provisions of those paragraphs is limited to the excess interest amount stated in that document.