This Act comes into effect on April 1, 2014; provided, however, that the provisions set forth in the following items come into effect on the dates specified in those items:

Except as otherwise provided in these Supplementary Provisions, the provisions of the Income Tax Act as amended by Article 1 (hereinafter referred to as the "new Income Tax Act" up to Article 22 and in Article 74 of the Supplementary Provisions) 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.

The provisions of Article 5, paragraph (2) of the new Income Tax Act apply to income tax for 2017 and subsequent years.

With regard to the income tax for 2016 and prior years of a Nonresident who, in any year up to and including 2016, falls under the case set forth in Article 5, paragraph (2), item (i) or (ii) of the Income Tax Act prior to the amendment by Article 1 (hereinafter referred to as the "former Income Tax Act" up to Article 22 and in Article 74 of the Supplementary Provisions), the provisions of that paragraph remain in force. In this case, the phrase "Article 161" in item (i) of that paragraph is deemed to be replaced with "Article 161 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act")", and the phrase "Article 161, item (i)-2" in item (ii) of that paragraph is deemed to be replaced with "Article 161, item (i)-2 of the former Income Tax Act".

The provisions of Article 7, paragraph (1) of the new Income Tax Act (limited to the part concerning items (ii) and (iii)) apply to income tax for 2017 and subsequent years.

With regard to the income tax for 2016 and prior years of a Non-Permanent Resident set forth in Article 7, paragraph (1), item (ii) of the former Income Tax Act who, in any year up to and including 2016, has the income specified in that item, or of a Nonresident set forth in item (iii) of that paragraph who has the income specified in that item, those provisions remain in force. In this case, the phrase "Article 161" in item (ii) of that paragraph is deemed to be replaced with "Article 161 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act")", and the phrase "each item of Article 164, paragraph (1)" in item (iii) of that paragraph is deemed to be replaced with "each item of Article 164, paragraph (1) of the former Income Tax Act", and beyond this, the technical replacement of terms in the provisions of laws and regulations concerning income tax in the case where the first sentence of this paragraph applies, and any other necessary matters concerning the application of the first sentence of this paragraph, are specified by Cabinet Order.

The provisions of Article 28 of the new Income Tax Act apply to income tax for 2016, and the provisions then in force continue to govern income tax for 2015 and prior years.

The provisions of Article 41-2 of the new Income Tax Act apply to a transfer of a right prescribed in that Article that is made on or after the date on which this Act comes into effect (hereinafter referred to as the "effective date").

The provisions of Article 57-2 of the new Income Tax Act apply to income tax for 2016 and subsequent years, and the provisions then in force continue to govern income tax for 2015 and prior years.

The provisions of Article 95 of the new Income Tax Act apply to income tax for 2017 and subsequent years.

With regard to the income tax for 2016 and prior years relating to the foreign tax credit under Article 95 of the former Income Tax Act of a Resident who, in any year up to and including 2016, is to pay foreign income taxes prescribed in paragraph (1) of that Article, the provisions of that Article remain in force.

In the case where the provisions of the preceding paragraph apply, the provisions set forth in the following items apply as specified in each of those items:

The provisions of Article 121, paragraph (3) of the new Income Tax Act apply to income tax for 2015 and subsequent years, and the provisions then in force continue to govern income tax for 2014 and prior years.

The provisions of Article 132, paragraph (2) of the new Income Tax Act apply to permission for deferred payment under paragraph (1) of that Article that is applied for on or after April 1, 2015, and the provisions then in force continue to govern permission for deferred payment under Article 132, paragraph (1) of the former Income Tax Act that was applied for before that date.

The provisions of Article 161 and Article 162, paragraph (2) of the new Income Tax Act apply to the income tax of a Nonresident for 2017 and subsequent years.

With regard to the income tax for 2016 and prior years of a Nonresident who, in any year up to and including 2016, has domestic source income prescribed in Article 161 of the former Income Tax Act, the provisions of that Article and Article 162 of the former Income Tax Act remain in force. In this case, the technical replacement of terms in the provisions of laws and regulations concerning income tax and any other necessary matters concerning the application of the first sentence of this paragraph are specified by Cabinet Order.

The provisions of Article 161, paragraph (1), items (iv) through (xi) and items (xiii) through (xvi) of the new Income Tax Act (limited to the cases where the provisions of Articles 178, 179 and 212 of the new Income Tax Act apply) apply to domestic source income set forth in Article 161, paragraph (1), items (iv) through (xi) or items (xiii) through (xvi) of the new Income Tax Act that a Foreign Corporation is to be paid on or after April 1, 2016, and the provisions then in force continue to govern domestic source income set forth in Article 161, items (i)-2 through (vii) or items (ix) through (xii) of the former Income Tax Act that a Foreign Corporation is to be paid before that date. In this case, for the purpose of applying the provisions of Article 161, paragraph (1) of the new Income Tax Act during the period from that date to December 31 of that year, the phrase "those specified by Cabinet Order" in item (iv) of that paragraph is deemed to be replaced with "those specified by Cabinet Order (limited to those falling under what is set forth in Article 161, item (i)-2 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (referred to as the "former Income Tax Act" in item (viii), (b)))", and the phrase "those relating" in item (viii), (b) of that paragraph is deemed to be replaced with "those relating (limited to those falling under what is set forth in Article 161, item (iv), (b) of the former Income Tax Act)".

The provisions of Article 164, paragraph (1) and Article 165 of the new Income Tax Act apply to income tax for 2017 and subsequent years.

With regard to the income tax for 2016 and prior years of a Nonresident set forth in an item of Article 164, paragraph (1) of the former Income Tax Act who, in any year up to and including 2016, has the domestic source income specified in that item, the provisions of that paragraph and Article 165 of the former Income Tax Act remain in force. In this case, the phrase "Subsection 1 of the following Section" in that paragraph is deemed to be replaced with "Part III, Chapter II, Section 2, Subsection 1 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act" in this paragraph and the following Article)", the phrase "domestic source income" in item (i) of that paragraph is deemed to be replaced with "domestic source income (meaning domestic source income prescribed in Article 161 of the former Income Tax Act; the same applies hereinafter in this paragraph)", the phrase "Article 161, item (i)" in items (ii) and (iii) of that paragraph is deemed to be replaced with "Article 161, item (i) of the former Income Tax Act", and the phrase "Article 161, item (iv)" is deemed to be replaced with "Article 161, item (iv) of the former Income Tax Act", the phrase "Article 161, item (i)" in item (iv), (a) of that paragraph is deemed to be replaced with "Article 161, item (i) of the former Income Tax Act", the phrase "Article 161, item (ii)" in (b) of that item is deemed to be replaced with "Article 161, item (ii) of the former Income Tax Act", and the phrase "each item of paragraph (1) of the preceding Article" in that Article is deemed to be replaced with "each item of Article 164, paragraph (1) of the former Income Tax Act", and the phrase "Chapters I through IV of the preceding Part" is deemed to be replaced with "Part II, Chapters I through IV of the former Income Tax Act".

In the case where the provisions of the preceding paragraph apply, the provisions set forth in the following items apply as specified in each of those items:

The provisions of Article 164, paragraph (2) and Articles 169 and 170 of the new Income Tax Act apply to income tax for 2017 and subsequent years.

With regard to the domestic source income specified in an item of Article 164, paragraph (2) of the former Income Tax Act that a Nonresident set forth in that item has on or before December 31, 2016, the provisions of that paragraph and Articles 169 and 170 of the former Income Tax Act remain in force. In this case, the phrase "Section 3" in that paragraph is deemed to be replaced with "Part III, Chapter II, Section 3 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act")", the phrase "Article 161, item (iv)" in each item of that paragraph is deemed to be replaced with "Article 161, item (iv) of the former Income Tax Act", the phrase "each item of Article 164, paragraph (2)" in Article 169 of the former Income Tax Act is deemed to be replaced with "each item of Article 164, paragraph (2) of the former Income Tax Act", the phrase "Article 161, item (iv)" in item (i) of that Article is deemed to be replaced with "Article 161, item (iv) of the former Income Tax Act", the phrase "Article 161, item (v)" in item (ii) of that Article is deemed to be replaced with "Article 161, item (v) of the former Income Tax Act", the phrase "Article 161, item (viii), (b)" in item (iii) of that Article is deemed to be replaced with "Article 161, item (viii), (b) of the former Income Tax Act", the phrase "Article 161, item (ix)" in item (iv) of that Article is deemed to be replaced with "Article 161, item (ix) of the former Income Tax Act", the phrase "Article 161, item (x)" in item (v) of that Article is deemed to be replaced with "Article 161, item (x) of the former Income Tax Act", and the phrase "Article 161, item (iv)" in Article 170 of the former Income Tax Act is deemed to be replaced with "Article 161, item (iv) of the former Income Tax Act".

With regard to the application of the provisions of Article 41-15-3, paragraph (3) of the Act on Special Measures Concerning Taxation in the case where the provisions of the preceding paragraph apply, the phrase "Part III, Chapter II, Section 3 of that Act and" in that paragraph is deemed to be replaced with "Part III, Chapter II, Section 3 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014; hereinafter referred to as the "2014 Amendment Act" in this paragraph) and the Income Tax Act", and the phrase "Article 169, item (iii) of that Act or" is deemed to be replaced with "Article 169, item (iii) of the Income Tax Act prior to the amendment by Article 1 of the 2014 Amendment Act, which remains in force pursuant to the provisions of Article 11, paragraph (5) of the Supplementary Provisions of the 2014 Amendment Act, or the Income Tax Act", and beyond this, the technical replacement of terms in the provisions of laws and regulations concerning income tax and any other necessary matters concerning the application of the provisions of the preceding paragraph are specified by Cabinet Order.

The provisions of Articles 165-2 through 165-6 of the new Income Tax Act apply to income tax for 2017 and subsequent years.

The provisions of Article 112, paragraph (2) of the new Income Tax Act as applied mutatis mutandis pursuant to Article 166 of the new Income Tax Act apply to the documents under paragraph (2) of that Article that are attached to a paper-based application under paragraph (1) of that Article submitted in any year from 2017 onward, and the provisions then in force continue to govern the documents under paragraph (2) of that Article that were attached to a paper-based application under Article 112, paragraph (1) of the former Income Tax Act as applied mutatis mutandis pursuant to Article 166 of the former Income Tax Act submitted in any year up to and including 2016.

The provisions of Article 145, item (ii) of the new Income Tax Act as applied mutatis mutandis pursuant to Article 166 of the new Income Tax Act apply in the case where there are facts falling under that item with regard to the books and documents under that item for any year from 2017 onward, and the provisions then in force continue to govern the case where there are facts falling under that item with regard to the books and documents under Article 145, item (ii) of the former Income Tax Act as applied mutatis mutandis pursuant to Article 166 of the former Income Tax Act for any year up to and including 2016.

The provisions of Article 166-2 of the new Income Tax Act apply to income tax for 2017 and subsequent years.

The provisions of Article 168-2 of the new Income Tax Act apply to acts or calculations that a Nonresident prescribed in that Article makes on or after January 1, 2017.

The provisions of Articles 178 and 179 of the new Income Tax Act apply to domestic source income prescribed in Article 178 of the new Income Tax Act that a Foreign Corporation is to be paid on or after April 1, 2016, and the provisions then in force continue to govern domestic source income prescribed in Article 178 of the former Income Tax Act that a Foreign Corporation is to be paid before that date. In this case, for the purpose of applying the provisions of Article 178 of the new Income Tax Act during the period from that date to December 31 of that year, the phrase "Article 161, paragraph (1), items (iv) through (xi)" in that Article is deemed to be replaced with "Article 161, paragraph (1), item (iv) (limited to those falling under what is set forth in Article 161, item (i)-2 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act" in this Article)), items (v) through (vii), item (viii) (limited to those falling under what is set forth in Article 161, item (iv) of the former Income Tax Act), items (ix) through (xi)".

The provisions of Article 180, paragraphs (1) through (3) of the new Income Tax Act apply to the covered domestic source income prescribed in paragraph (1) of that Article that a Foreign Corporation prescribed in that paragraph is to be paid on or after April 1, 2016, and the provisions then in force continue to govern the domestic source income specified in an item of Article 180, paragraph (1) of the former Income Tax Act that a corporation set forth in that item is to be paid before that date.

The provisions of Appended Tables II through V of the new Income Tax Act apply to salary, etc. prescribed in Article 183, paragraph (1) of the new Income Tax Act that is to be paid on or after January 1, 2016, and the provisions then in force continue to govern salary, etc. prescribed in Article 183, paragraph (1) of the former Income Tax Act that is to be paid before that date.

The provisions of Article 203-3 of the new Income Tax Act apply to public pensions or retirement packages prescribed in Article 203-2 of the new Income Tax Act that are to be paid on or after October 1, 2015, and the provisions then in force continue to govern public pensions or retirement packages prescribed in Article 203-2 of the former Income Tax Act that are to be paid before that date.

The provisions of Article 212 of the new Income Tax Act apply to domestic source income prescribed in paragraph (1) of that Article that is to be paid on or after April 1, 2016, and the provisions then in force continue to govern domestic source income prescribed in Article 212, paragraph (1) of the former Income Tax Act that is to be paid before that date. In this case, for the purpose of applying the provisions of Article 212 of the new Income Tax Act during the period from that date to December 31 of that year, the phrase "Article 161, paragraph (1), items (iv) through (xvi)" in paragraph (1) of that Article is deemed to be replaced with "Article 161, paragraph (1), item (iv) (limited to those falling under what is set forth in Article 161, item (i)-2 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act" in this paragraph)), items (v) through (vii), item (viii) (limited to those falling under what is set forth in Article 161, item (iv) of the former Income Tax Act), or items (ix) through (xvi)", and the phrase "items (iv) through (xi) of that paragraph" is deemed to be replaced with "item (iv) of that paragraph (limited to those falling under what is set forth in Article 161, item (i)-2 of the former Income Tax Act), items (v) through (vii), item (viii) (limited to those falling under what is set forth in Article 161, item (iv) of the former Income Tax Act), items (ix) through (xi)".

The provisions of Article 214, paragraphs (1) through (3) of the new Income Tax Act apply to the covered domestic source income prescribed in paragraph (1) of that Article that a Nonresident prescribed in that paragraph is to be paid on or after January 1, 2017.

With regard to the domestic source income specified in an item of Article 214, paragraph (1) of the former Income Tax Act that a person set forth in that item is to be paid on or before December 31, 2016, the provisions of paragraphs (1) through (3) of that Article remain in force. In this case, the phrase "Article 164, paragraph (1), item (i)" in paragraph (1), item (i) of that Article is deemed to be replaced with "Article 164, paragraph (1), item (i) of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the "former Income Tax Act" in this paragraph)", the phrase "Article 161, item (i)-2" is deemed to be replaced with "Article 161, item (i)-2 of the former Income Tax Act", the phrase "Article 164, paragraph (1), item (ii)" in item (ii) of that paragraph is deemed to be replaced with "Article 164, paragraph (1), item (ii) of the former Income Tax Act", and the phrase "Article 164, paragraph (1), item (iii)" in item (iii) of that paragraph is deemed to be replaced with "Article 164, paragraph (1), item (iii) of the former Income Tax Act".

With regard to the application of the provisions of Article 41-22, paragraph (2) of the Act on Special Measures Concerning Taxation in the case where the provisions of the preceding paragraph apply, the phrase "of Article 214" in item (ii) of that paragraph is deemed to be replaced with "of Article 214 of the Income Tax Act prior to the amendment by Article 1 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014), which remains in force pursuant to the provisions of Article 19, paragraph (3) of the Supplementary Provisions of that Act (hereinafter referred to as the "former Income Tax Act" in this item)", the phrase "Article 172, paragraph (1) of that Act" is deemed to be replaced with "Article 172, paragraph (1) of the Income Tax Act", and the phrase "Article 214, paragraph (1) of that Act" is deemed to be replaced with "Article 214, paragraph (1) of the former Income Tax Act", and beyond this, the technical replacement of terms in the provisions of laws and regulations concerning income tax and any other necessary matters concerning the application of the provisions of the preceding paragraph are specified by Cabinet Order.

The provisions of Article 224, paragraph (6) of the new Income Tax Act apply to interest, dividends or distributions of proceeds prescribed in paragraph (2) of that Article, or redemption money prescribed in paragraph (4) of that Article, that is received on or after the effective date.

The provisions of Article 224-3, paragraph (1) of the new Income Tax Act apply to a transfer of shares or similar interests prescribed in paragraph (2) of that Article that is made on or after the effective date, and the provisions then in force continue to govern a transfer of shares or similar interests prescribed in Article 224-3, paragraph (2) of the former Income Tax Act that was made before the effective date.

The provisions of Article 228-4, paragraph (3) of the new Income Tax Act apply to the matters to be entered, as prescribed in paragraph (1) of that Article, of reports, etc. prescribed in that paragraph that are provided on or after the effective date.

The provisions of Article 232, paragraph (1) of the new Income Tax Act apply to transactions prescribed in that paragraph that a Nonresident who conducts the operations prescribed in that paragraph in Japan conducts on or after January 1, 2017, and the provisions then in force continue to govern transactions under that paragraph that a Nonresident prescribed in Article 232, paragraph (1) of the former Income Tax Act conducted before that date.

The provisions of Article 28 of the Income Tax Act as amended by Article 2 (referred to as "the 2017 Income Tax Act" in the following Article) apply to income tax for 2017 and subsequent years, and the provisions then in force continue to govern income tax for 2016.

The provisions of Appended Tables II through V of the 2017 Income Tax Act apply to salary or other wages prescribed in Article 183, paragraph (1) of the 2017 Income Tax Act that are to be paid on or after January 1, 2017, and the provisions then in force continue to govern salary or other wages prescribed in Article 183, paragraph (1) of the Income Tax Act prior to the amendment by Article 2 that are to be paid before that date.

With regard to the application of penal provisions to acts committed before this Act comes into effect (or, for the provisions set forth in the items of Article 1 of the Supplementary Provisions, before those provisions come into effect; the same applies hereinafter in this Article) and to acts committed after this Act comes into effect in the cases where the provisions then in force continue to govern pursuant to the provisions of these Supplementary Provisions, the provisions then in force continue to govern.

Beyond what is provided for in these Supplementary Provisions, transitional measures necessary for the enforcement of this Act are specified by Cabinet Order.