①Where a corporation that files a blue return has, in each business year beginning during the period from April 1, 2025 to March 31, 2032 (hereinafter referred to in this paragraph as a "covered business year"), conducted a patent right transfer transaction, etc. (meaning the transfer of specified patent rights, etc. to a resident (meaning a resident prescribed in Article 2, paragraph (1), item (i)-2) or a domestic corporation (excluding one that is a related party), or the lending of specified patent rights, etc. to another person (excluding one that is a related party; the same applies hereinafter in this paragraph) (including the creation of rights pertaining to specified patent rights, etc. and any other act of allowing another person to use specified patent rights, etc.); the same applies hereinafter in this paragraph), the amount equivalent to 30 percent of the smaller of the following amounts is included in deductible expenses in calculating the amount of income for that covered business year.

②In this Article, the meanings of the terms listed in the following items are as prescribed respectively in those items:

③Where the provisions of paragraph (1) are applied to each business year of a group tax sharing corporation that is a corporation referred to in that paragraph (limited to a business year ending on the day of the end of the business year of the group tax sharing parent corporation pertaining to that group tax sharing corporation), the amount listed in item (ii) of that paragraph is the amount specified by Cabinet Order as the amount of income of that group tax sharing corporation calculated pursuant to the provisions of Article 64-5 and Article 64-7 of the Corporation Tax Act on the basis of the income before group tax sharing and the deficit before group tax sharing prescribed in Article 64-5, paragraph (1) of that Act for that business year, or for the business year ending on that day, of that group tax sharing corporation and the other group tax sharing corporations (limited to those that have a group tax sharing full controlling interest with that group tax sharing corporation on that day).

④Where a corporation referred to in paragraph (1) has, in any business year, conducted a patent right acquisition transaction, etc. with a related party of that corporation, if the amount of consideration paid by that corporation to that related party for that patent right acquisition transaction, etc. is less than the arm's length price, that patent right acquisition transaction, etc. is deemed to have been conducted at the arm's length price with regard to the application of the provisions of that paragraph for that business year and each subsequent business year of that corporation.

⑤The arm's length price prescribed in the preceding paragraph means the amount calculated for the amount of consideration for a patent right acquisition transaction, etc. in a manner equivalent to the methods prescribed in Article 66-4, paragraph (2) (where that patent right acquisition transaction, etc. is a transaction with a foreign affiliate prescribed in paragraph (1) of that Article, the arm's length price prescribed in that paragraph).

⑥In the case specified by Cabinet Order as the case where a corporation referred to in paragraph (1) conducts a patent right acquisition transaction, etc. with a related party of that corporation via another person (excluding any other related party of that corporation; hereinafter referred to in this paragraph as a "non-affiliate"), the patent right acquisition transaction, etc. between that corporation and that non-affiliate is deemed to be a patent right acquisition transaction, etc. conducted between that corporation and that related party, and the provisions of paragraph (4) apply.

⑦Where a corporation that seeks the application of the provisions of paragraph (1) has, in the relevant business year, conducted a patent right acquisition transaction, etc. (excluding one that falls under a transaction with a foreign affiliate prescribed in Article 66-4, paragraph (1); the same applies hereinafter through paragraph (11)) with a related party of that corporation, the corporation must prepare or obtain the documents specified by Order of the Ministry of Finance as documents found to be necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to that patent right acquisition transaction, etc. (including, where an electronic or magnetic record (meaning a record used in computer data processing that is created in electronic form, magnetic form or any other form that cannot be perceived by the human senses; the same applies hereinafter in this Article) has been prepared in lieu of preparing those documents, that electronic or magnetic record) by the due date for filing the return under Article 74, paragraph (1) or Article 144-6, paragraph (1) or paragraph (2) of the Corporation Tax Act for that business year (where the business year in which that patent right acquisition transaction, etc. was conducted is a business year that began before April 1, 2025, the first business year beginning on or after that date), and must retain them as specified by Order of the Ministry of Finance.

⑧The provisions of the preceding paragraph do not apply to the documents found to be necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to the patent right acquisition transactions, etc. conducted by a corporation referred to in the preceding paragraph with a single related party in the relevant business year, in the case where the total amount of consideration paid to that single related party for the patent right acquisition transactions, etc. conducted by that corporation with that single related party in the business year preceding the relevant business year (where there is no preceding business year or in any other case specified by Cabinet Order, the patent right acquisition transactions, etc. conducted by that corporation with that single related party in the relevant business year) is less than 300 million yen, or in the case specified by Cabinet Order as the case where there were no patent right acquisition transactions, etc. conducted by that corporation with that single related party in the preceding business year, nor to the documents found to be necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to the patent right acquisition transactions, etc. conducted by a corporation referred to in the preceding paragraph with a related party of that corporation in the relevant business year, in the case where no amount of research and development expenses arises from those patent right acquisition transactions, etc. or where the amount of research and development expenses arising from those patent right acquisition transactions, etc. is not expected to form the basis for calculating the amount to be included in deductible expenses pursuant to the provisions of paragraph (1).

⑨Where the relevant official of the National Tax Agency, or the relevant official of the tax office or Regional Taxation Bureau with jurisdiction over the place for tax payment of a corporation, has requested the corporation to present or submit the documents specified by Order of the Ministry of Finance prescribed in paragraph (7) pertaining to a patent acquisition transaction, etc. subject to contemporaneous documentation (meaning a patent right acquisition transaction, etc. other than a patent right acquisition transaction, etc. to which the provisions of the preceding paragraph apply; the same applies hereinafter in this paragraph) in each business year (including, where an electronic or magnetic record has been prepared or retained in lieu of preparing or retaining those documents, that electronic or magnetic record; the same applies hereinafter in this paragraph) or copies thereof, and they are not presented or submitted by the day designated by that official, taking into account the number of days normally required to prepare the presentation or submission of the documents or copies requested, within a period not exceeding 45 days from the day on which the presentation or submission was requested, or has requested the corporation to present or submit the documents specified by Order of the Ministry of Finance as documents found to be important for calculating the arm's length price prescribed in paragraph (4) (including an amount deemed to be that arm's length price pursuant to the provisions of the main clause of Article 66-4, paragraph (8) as applied mutatis mutandis pursuant to paragraph (14)) pertaining to a patent acquisition transaction, etc. subject to contemporaneous documentation in each business year (including, where an electronic or magnetic record has been prepared or retained in lieu of preparing or retaining those documents, that electronic or magnetic record; the same applies hereinafter in this paragraph) or copies thereof, and they are not presented or submitted by the day designated by that official, taking into account the number of days normally required to prepare the presentation or submission of the documents or copies requested, within a period not exceeding 60 days from the day on which the presentation or submission was requested, that official may, if it is necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to the patent acquisition transaction, etc. subject to contemporaneous documentation of that corporation in each business year, to the extent found necessary, ask questions of a person engaged in a business of the same type as the business of that corporation pertaining to that patent acquisition transaction, etc. subject to contemporaneous documentation, inspect the books and documents concerning that business (including, where an electronic or magnetic record has been prepared or retained in lieu of preparing or retaining those books and documents, that electronic or magnetic record; the same applies hereinafter in this Article), or request the presentation or submission of those books and documents (including copies thereof).

⑩Where the relevant official of the National Tax Agency, or the relevant official of the tax office or Regional Taxation Bureau with jurisdiction over the place for tax payment of a corporation, has requested the corporation to present or submit the documents specified by Order of the Ministry of Finance as documents found to be important for calculating the arm's length price prescribed in paragraph (4) (including an amount deemed to be that arm's length price pursuant to the provisions of the main clause of Article 66-4, paragraph (8) as applied mutatis mutandis pursuant to paragraph (14)) pertaining to a patent acquisition transaction, etc. exempt from contemporaneous documentation (meaning a patent right acquisition transaction, etc. to which the provisions of paragraph (8) apply; the same applies hereinafter in this paragraph) in each business year (including, where an electronic or magnetic record has been prepared or retained in lieu of preparing or retaining those documents, that electronic or magnetic record; the same applies hereinafter in this paragraph) or copies thereof, if they are not presented or submitted by the day designated by that official, taking into account the number of days normally required to prepare the presentation or submission of the documents or copies requested, within a period not exceeding 60 days from the day on which the presentation or submission was requested, that official may, if it is necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to the patent acquisition transaction, etc. exempt from contemporaneous documentation of that corporation in each business year, to the extent found necessary, ask questions of a person engaged in a business of the same type as the business of that corporation pertaining to that patent acquisition transaction, etc. exempt from contemporaneous documentation, inspect the books and documents concerning that business, or request the presentation or submission of those books and documents (including copies thereof).

⑪The relevant official of the National Tax Agency, or the relevant official of the tax office or Regional Taxation Bureau with jurisdiction over the place for tax payment of a corporation may, if it is necessary for calculating the arm's length price prescribed in paragraph (4) pertaining to the patent right acquisition transactions, etc. of the corporation, retain the books and documents (including copies thereof) submitted pursuant to the provisions of the preceding two paragraphs.

⑫The authority of the relevant official under the provisions of the preceding three paragraphs must not be construed as being granted for the purpose of a criminal investigation.

⑬The relevant official of the National Tax Agency, the Regional Taxation Bureau, or the tax office, when asking questions, conducting an inspection, or requesting presentation or submission pursuant to the provisions of paragraph (9) or paragraph (10), must carry an identification card and present it to the person concerned when requested.

⑮The provisions of paragraph (1) apply only where the final return, etc. for the business year for which the corporation seeks the application of those provisions contains a statement of the inclusion in deductible expenses of the amount to be included in deductible expenses pursuant to those provisions, and a written statement concerning the calculation of the amount to be included in deductible expenses, a document stating, where the transactions forming the basis for the calculation of the amount to be included in deductible expenses include a patent right acquisition transaction, etc. conducted with a related party of the corporation, the name of that related party, the location of its head office or principal office and other matters specified by Order of the Ministry of Finance, and other documents specified by Order of the Ministry of Finance (referred to in the following paragraph as the "detailed statement, etc.") are attached to that final return, etc. In this case, the amount to be included in deductible expenses pursuant to the provisions of paragraph (1) is limited to the amount to be included in deductible expenses pertaining to that statement.

⑯Even where a final return, etc. without the statement or attachment referred to in the preceding paragraph has been filed, if the district director finds that there were unavoidable circumstances for the absence of the statement or attachment, the district director may apply the provisions of paragraph (1), but only if a document containing that statement and the detailed statement, etc. are submitted.

⑰With regard to the application of the provisions of Article 67, paragraph (3) and paragraph (5) of the Corporation Tax Act, any amount included, pursuant to the provisions of paragraph (1), in the amount of deductible expenses of a corporation subject to the provisions of the paragraph is to be included in the amount of income, etc. prescribed in these provisions.

⑱Beyond what is provided for in paragraph (2) and the preceding three paragraphs, the calculation of the amount of revenue reserves of a corporation to which the provisions of paragraph (1) have been applied, the procedures concerning the retention of the books and documents (including copies thereof) referred to in paragraph (9) and paragraph (10), and other necessary matters concerning the application of the provisions of paragraph (1), paragraphs (3) through (8), paragraph (11) or paragraph (14) are specified by Cabinet Order.