Supplementary Provisions, Article 21

With respect to a corporation to which Article 72-18, paragraph (2) of the Former Act applied, where the amount expended by the disposition of surplus, such as dividends and bonuses, in each business year beginning within three years from the beginning of the business year of the corporation that includes the date of enforcement of this Act exceeds the amount specified by Cabinet Order as the amount of income for that business year, the amount specified by Cabinet Order as the part of the excess consisting of amounts that were not treated as income constituting the tax base under Article 72-18, paragraph (2) of the Former Act is to be included in gross profits in calculating the income for the business year relating to that disposition of surplus.