①Where a specific purpose company prescribed in Article 2, paragraph (3) of the Act on the Securitization of Assets (hereinafter referred to as the "Asset Securitization Act" in this paragraph) (hereinafter referred to as a "specific purpose company" in this Article) that satisfies the requirements listed in item (i) pays dividends of profits (including distributions of monies prescribed in Article 115, paragraph (1) of the Asset Securitization Act; hereinafter the same applies in this paragraph), the amount of those dividends of profits (including, where the amount of money delivered to its investors by that specific purpose company due to the grounds listed in Article 24, paragraph (1), items (iv) through (vi) of the Corporation Tax Act exceeds the amount specified by Cabinet Order as the amount of the portion, out of the amount of stated capital, etc. of that specific purpose company prescribed in Article 2, item (xvi) of that Act, corresponding to the contribution to that specific purpose company that gave rise to the delivery, the amount of the excess; hereinafter the same applies in this paragraph and paragraph (4)) that pertains to a business year that satisfies the requirements listed in item (ii) (hereinafter referred to as a "business year of application" in this paragraph) is included in deductible expenses in calculating the amount of income for that business year of application; provided, however, that where the amount of those dividends of profits exceeds the amount specified by Cabinet Order as the amount of income for that business year of application, the amount to be included in deductible expenses is limited to the amount so specified by Cabinet Order.

③With regard to the application of the provisions of Article 62-3, paragraph (3), Article 66-8, paragraphs (1) and (7), and Article 66-9-4, paragraphs (1) and (6) to a specific purpose company, the phrase "falls under" in Article 62-3, paragraph (3) is deemed to be replaced with "falls under, and a transfer made by a specific purpose company prescribed in Article 2, paragraph (3) of the Act on the Securitization of Assets in a business year that satisfies the requirements listed in Article 67-14, paragraph (1), item (ii) (excluding (e))", the phrase "a foreign corporation (excluding one that falls under a foreign subsidiary prescribed in Article 23-2, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this paragraph)" in Article 66-8, paragraph (1) is deemed to be replaced with "a foreign corporation", the phrase "that Act" is deemed to be replaced with "the Corporation Tax Act", the phrase "a foreign corporation (excluding one that falls under a foreign subsidiary prescribed in Article 23-2, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this paragraph)" in paragraph (7) of that Article is deemed to be replaced with "a foreign corporation", the phrase "a foreign corporation (excluding one that falls under a foreign subsidiary prescribed in Article 23-2, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this paragraph)" in Article 66-9-4, paragraph (1) is deemed to be replaced with "a foreign corporation", the phrase "that Act" is deemed to be replaced with "the Corporation Tax Act", and the phrase "a foreign corporation (excluding one that falls under a foreign subsidiary prescribed in Article 23-2, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this paragraph)" in paragraph (6) of that Article is deemed to be replaced with "a foreign corporation".

④The provisions of Article 23, paragraph (1) of the Corporation Tax Act do not apply to the amount of dividends of profits that a corporation receives from a specific purpose company.

⑤The provisions of Article 62-4, paragraph (1) of the Corporation Tax Act do not apply to a transfer of assets or liabilities by a corporation to a specific purpose company through a capital contribution in kind.

⑥The provisions of paragraph (1) apply only if the final return, etc. for the business year for which the corporation seeks the application of the provisions of that paragraph contains a statement concerning the inclusion in deductible expenses of the amount to be included in deductible expenses pursuant to the provisions of that paragraph and has attached to it a written statement concerning the calculation of the amount to be included in deductible expenses, and the corporation preserves documents that make clear that it satisfies the requirements listed in paragraph (1), item (i), (b) and (c).

⑦Even where a final return, etc. has been filed without the statement or the written statement set forth in the preceding paragraph attached thereto, or the documents set forth in that paragraph have not been preserved, the district director may, when the district director finds any unavoidable reason for the failure to make the statement, attach the written statement or preserve the documents, apply the provisions of paragraph (1).

⑧Beyond what is provided for in the preceding two paragraphs, necessary matters concerning the application of the provisions of paragraphs (1) through (5) and other necessary matters concerning the application of the provisions of laws and regulations concerning corporation tax to specific purpose companies and their members are specified by Cabinet Order.