①The provisions of Article 64, paragraph (3) of the New Act on Special Measures Concerning Taxation (including as applied mutatis mutandis pursuant to paragraph (10) of that Article (including as applied mutatis mutandis pursuant to Article 65, paragraph (3) of the New Act on Special Measures Concerning Taxation) and Article 65, paragraph (3) of the New Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) apply to assets that are to be substitute assets prescribed in Article 64, paragraph (3) of the New Act on Special Measures Concerning Taxation relating to an expropriation, etc. (meaning an expropriation, etc. prescribed in Article 64, paragraph (1) of the New Act on Special Measures Concerning Taxation (including as applied mutatis mutandis pursuant to Article 65, paragraph (3) of the New Act on Special Measures Concerning Taxation)) to which a corporation is subjected on or after the Effective Date.

②The provisions of Article 65-3, paragraph (1) of the New Act on Special Measures Concerning Taxation (limited to the part concerning item (vii)) apply in the case where land, etc. prescribed in that paragraph held by a corporation is purchased on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, and the provisions then in force continue to govern the case where land, etc. prescribed in Article 65-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation held by a corporation was purchased before that date.

③If, on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, agricultural land prescribed in Article 65-3, paragraph (1), item (vii) of the Former Act on Special Measures Concerning Taxation that is located within the implementation area of an agricultural land use improvement project prescribed in Article 23-2, paragraph (1) of the Former Act on Promotion of Improvement of Agricultural Management Foundation, relating to the agricultural land use rules prescribed in Article 6, paragraph (3) of the Supplementary Provisions of the Agricultural Management Foundation Act, etc. Amendment Act in the case where the provisions then in force continue to govern pursuant to that paragraph, is purchased by the farmland intermediary management organization referred to in Article 23-2, paragraph (6) of the Former Act on Promotion of Improvement of Agricultural Management Foundation (limited to a farmland intermediary management organization prescribed in that item) based on a request under that paragraph in the case where the provisions then in force continue to govern pursuant to the provisions of Article 6, paragraph (3) of the Supplementary Provisions of the Agricultural Management Foundation Act, etc. Amendment Act, that case of purchase is deemed to fall under the case listed in Article 65-3, paragraph (1), item (vii) of the New Act on Special Measures Concerning Taxation, and the provisions of that Article apply.

④With regard to the application of the provisions of Article 65-4 of the New Act on Special Measures Concerning Taxation in the case where the provisions of the preceding paragraph apply, the phrase "case" in paragraph (1), item (xxv) of that Article is deemed to be replaced with "case (excluding a case that falls under the case listed in paragraph (1), item (vii) of the preceding Article as applied by deeming pursuant to the provisions of Article 47, paragraph (3) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 4 of 2022))".

⑤The provisions of Article 65-4, paragraph (1) of the New Act on Special Measures Concerning Taxation (limited to the part concerning item (xxv)) apply in the case where land, etc. prescribed in that paragraph held by a corporation is purchased on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, and the provisions then in force continue to govern the case where land, etc. prescribed in Article 65-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation held by a corporation was purchased before that date.

⑥If, on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, agricultural land prescribed in Article 65-4, paragraph (1), item (xxv) of the Former Act on Special Measures Concerning Taxation that is located within the area designated as an agricultural land area prescribed in that item is purchased by the farmland intermediary management organization referred to in Article 16, paragraph (2) of the Former Act on Promotion of Improvement of Agricultural Management Foundation (limited to a farmland intermediary management organization prescribed in that item) based on the consultation under that paragraph in the case where the provisions then in force continue to govern pursuant to the provisions of Article 3, paragraph (2) of the Supplementary Provisions of the Agricultural Management Foundation Act, etc. Amendment Act (excluding a case that falls under the case listed in Article 65-3, paragraph (1), item (vii) of the New Act on Special Measures Concerning Taxation (including as applied by deeming pursuant to the provisions of paragraph (3))), that case of purchase is deemed to fall under the case listed in Article 65-4, paragraph (1), item (xxv) of the New Act on Special Measures Concerning Taxation, and the provisions of that Article apply.

⑦The provisions of Article 65-5, paragraph (1) of the New Act on Special Measures Concerning Taxation (limited to the part concerning item (ii)) apply to corporation tax on a transfer of land, etc. prescribed in that paragraph that a qualified farmland-owning corporation prescribed in that paragraph makes on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, and the provisions then in force continue to govern corporation tax on a transfer of land, etc. prescribed in that paragraph that a qualified farmland-owning corporation prescribed in Article 65-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation made before that date.

⑧If, on or after the date specified in Article 1, item (xi) of the Supplementary Provisions, land, etc. prescribed in Article 65-5, paragraph (1), item (ii) of the Former Act on Special Measures Concerning Taxation is transferred under the agricultural land use consolidation plan prescribed in Article 5, paragraph (2) of the Supplementary Provisions of the Agricultural Management Foundation Act, etc. Amendment Act that remains in force pursuant to the provisions of that paragraph (excluding the case where the provisions of Article 65-3, paragraph (1), item (vii) (including as applied by deeming pursuant to the provisions of paragraph (3)) or Article 65-4, paragraph (1), item (xxv) (including as applied by deeming pursuant to the provisions of paragraph (6)) of the New Act on Special Measures Concerning Taxation apply), that case of transfer is deemed to fall under the case listed in Article 65-5, paragraph (1), item (ii) of the New Act on Special Measures Concerning Taxation, and the provisions of that Article apply.

⑨The provisions then in force continue to govern corporation tax on a transfer of land, etc. prescribed in item (iii) of Article 65-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a qualified farmland-owning corporation prescribed in that paragraph made before the Effective Date.

⑩The provisions then in force continue to govern corporation tax on a transfer of land prescribed in item (iv) of Article 65-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a qualified farmland-owning corporation prescribed in that paragraph made before the Effective Date.

⑪The provisions then in force continue to govern corporation tax on a transfer prescribed in Article 65-10, paragraph (1) of the Former Act on Special Measures Concerning Taxation of land, etc. prescribed in that paragraph by exchange and consolidation prescribed in item (ii) of that paragraph that a corporation made before the Effective Date.

⑫The provisions then in force continue to govern corporation tax on a transfer of other land, etc. prescribed in Article 66-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation made within 10 years after the end of the business year that includes the day of the acquisition prescribed in that paragraph.

The provisions of Article 67-5, paragraph (1) of the New Act on Special Measures Concerning Taxation (excluding the part concerning a group tax sharing corporation referred to in that paragraph) apply to low-value depreciable assets prescribed in that paragraph that a small and medium sized enterprise, etc. prescribed in that paragraph acquires, or manufactures or constructs, on or after the Effective Date, and the provisions then in force continue to govern low-value depreciable assets prescribed in that paragraph that a small and medium sized enterprise, etc. prescribed in Article 67-5, paragraph (1) of the Former Act on Special Measures Concerning Taxation acquired, or manufactured or constructed, before the Effective Date.

The provisions then in force continue to govern domestic source income prescribed in Article 67-16-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation of a foreign corporation referred to in that paragraph for business years that began before January 1, 2022.

The provisions of Article 68-2 of the New Act on Special Measures Concerning Taxation apply to a merger listed in any of the items of that Article that is carried out on or after the Effective Date, and the provisions then in force continue to govern a merger listed in any of the items of Article 68-2 of the Former Act on Special Measures Concerning Taxation that was carried out before the Effective Date.