①Where a research and development partnership that files a blue return (excluding one in liquidation) has, by March 31, 2027, levied, pursuant to the provisions of Article 9, paragraph (1) of the Research and Development Partnerships Act (Act No. 81 of 1961), charges to cover the costs of acquiring or manufacturing fixed assets specified by Cabinet Order that are directly used for experimental research prescribed in Article 3, paragraph (1), item (i) of that Act (limited to research conducted in order to obtain new knowledge or to devise new applications of available knowledge) (hereinafter referred to in this Article as "assets for experimental research"), and has acquired or manufactured assets for experimental research in the business year in which the amount based on that levy was paid, with an amount equivalent to all or part of the amount so paid, if the partnership has reduced the book value of those assets for experimental research through accounting as an expense or loss within the range of the amount obtained by deducting, from their acquisition cost, one yen (if the acquisition cost of those assets for experimental research exceeds the amount so paid (if any amount has already been applied to the acquisition or manufacture of assets for experimental research, the amount obtained by deducting that amount), the excess amount), the amount equivalent to the reduced amount is included in deductible expenses in calculating the amount of income for the business year that includes the date of the acquisition or manufacture.

②The provisions of the preceding paragraph apply only if the final return, etc. contains a statement regarding the inclusion in deductible expenses of the amount to be included in deductible expenses pursuant to the provisions of that paragraph, and a written statement concerning the calculation of the amount to be included in deductible expenses is attached to that final return, etc.

③In applying the provisions of laws and regulations concerning corporation tax to assets for experimental research to which the provisions of paragraph (1) have been applied, the amount included in deductible expenses in calculating the amount of income for each business year pursuant to the provisions of that paragraph is not included in the acquisition cost of those assets for experimental research.

④Beyond what is prescribed in the preceding two paragraphs, Cabinet Order provides for the necessary particulars concerning the application of the provisions of paragraph (1).

①Where a corporation has paid, in any business year, any of the following contributions or premiums pertaining to a fund or trust property that is used or managed over a long period of time, the amount paid is included in deductible expenses in calculating the amount of income for that business year:

②The provisions of the preceding paragraph (limited to the part pertaining to item (ii)) do not apply to the premiums listed in that item that a corporation which, after the cancellation of a mutual aid contract prescribed in that item that it had concluded, has concluded a mutual aid contract prescribed in that item pays for that mutual aid contract during the period from the day of the cancellation until the day on which two years have elapsed from that day.

③The provisions of paragraph (1) do not apply if a written statement concerning the inclusion in deductible expenses of the amount prescribed in that paragraph is not attached to the final return, etc.; provided, however, that this does not apply where, even if a final return, etc. without that attachment has been filed, the district director finds that there was an unavoidable reason for the absence of the attachment and the written statement is submitted.

①With regard to the application of the provisions of Article 37 of the Corporation Tax Act as applied with the replacement of terms pursuant to the provisions of Article 70, paragraph (1) of the Act on Promotion of Specified Non-profit Activities in the case where a corporation that, at the end of the business year, is a certified specified nonprofit corporation prescribed in Article 2, paragraph (3) of that Act (referred to as a "certified specified nonprofit corporation" in the following paragraph) has an amount that it has expended, out of the assets belonging to its profit-making business, for a business other than that profit-making business that falls under a business pertaining to specified non-profit activity (meaning specified non-profit activity prescribed in paragraph (1) of that Article; the same applies in the following paragraph and paragraph (3)), the phrase "a public interest corporation, etc." in the proviso to paragraph (4) of that Article is deemed to be replaced with "a public interest corporation, etc. or a certified specified nonprofit corporation (meaning a certified specified nonprofit corporation prescribed in Article 66-11-3, paragraph (1) (Special Provisions on Inclusion in Deductible Expenses, etc. of Donations to Certified Specified Nonprofit Corporations) of the Act on Special Measures Concerning Taxation; the same applies in the following paragraph and paragraph (6))", the phrase "a public interest corporation, etc." in the proviso to paragraph (5) of that Article is deemed to be replaced with "a public interest corporation, etc. or a certified specified nonprofit corporation", the phrase "a public interest corporation, etc." in paragraph (6) of that Article is deemed to be replaced with "a public interest corporation, etc. or a certified specified nonprofit corporation", the phrase "にあつては、" (in the case of, followed by a comma) is deemed to be replaced with "にあつては" (in the case of, without the comma), and the phrase "amount)" is deemed to be replaced with "amount, and for a certified specified nonprofit corporation, the amount it has expended, out of the assets belonging to its profit-making business, for a business other than that profit-making business that falls under a business pertaining to specified non-profit activity prescribed in Article 66-11-3, paragraph (1) of the Act on Special Measures Concerning Taxation)".

②With regard to the application of the provisions of Article 37 of the Corporation Tax Act in the case where the amount of donations paid by a corporation (excluding a corporation to which the provisions of the preceding paragraph apply) in each business year includes the amount of donations to a certified specified nonprofit corporation, etc. (meaning a certified specified nonprofit corporation and a special certified specified nonprofit corporation prescribed in Article 2, paragraph (4) of the Act on Promotion of Specified Non-profit Activities; hereinafter the same applies in this paragraph) related to a business pertaining to specified non-profit activity conducted by that certified specified nonprofit corporation, etc., the phrase ") exists, those donations" in paragraph (4) of that Article is deemed to be replaced with "; hereinafter the same applies in this paragraph) and the amount of donations to a certified specified nonprofit corporation, etc. (meaning a certified specified nonprofit corporation, etc. prescribed in Article 66-11-3, paragraph (2) (Special Provisions on Inclusion in Deductible Expenses, etc. of Donations to Certified Specified Nonprofit Corporations) of the Act on Special Measures Concerning Taxation) related to a business pertaining to specified non-profit activity prescribed in paragraph (2) of that Article conducted by that certified specified nonprofit corporation, etc. exist, these donations".

③Where a corporation that has received the certification under Article 44, paragraph (1) of the Act on Promotion of Specified Non-profit Activities has had that certification revoked, an amount equivalent to the total of the amounts that the corporation expended, in each business year from the business year that includes the day specified by Cabinet Order as the day on which the fact giving rise to the revocation arose until the business year preceding the business year that includes the date of the revocation (limited to business years that ended within seven years before the end of the business year that includes the date of the revocation; hereinafter the same applies in this paragraph), out of the assets belonging to its profit-making business, for a business other than that profit-making business that falls under a business pertaining to specified non-profit activity, and that were included in deductible expenses in calculating the amount of income for each of those business years, is deemed to be the amount of revenue arising from the profit-making business conducted by the corporation in the business year that includes the date of the revocation.

④In the case referred to in the preceding paragraph, if the corporation referred to in that paragraph is not conducting a profit-making business on the date of the revocation, the corporation is deemed to have newly commenced a profit-making business on the date of the revocation. In this case, the provisions of Article 66, paragraph (4) of the Corporation Tax Act and the provisions of Article 42-3-2, paragraph (3) do not apply for the business year that includes the date of the revocation.

⑤Beyond what is prescribed in the preceding paragraph, Cabinet Order provides for the amount calculated in the manner specified by Cabinet Order prescribed in Article 37, paragraph (1) of the Corporation Tax Act in the case where a certified specified nonprofit corporation prescribed in paragraph (1) applies the provisions of paragraph (1) of that Article by reading the provisions of paragraph (6) of that Article with the replacement of terms pursuant to the provisions of paragraph (1), and other necessary particulars concerning the application of the provisions of paragraphs (1) through (3).

①Where the provisions of Article 57, paragraph (1) of the Corporation Tax Act apply in each business year beginning on or before March 31, 2032 of the Banks' Shareholdings Purchase Corporation filing a blue return, if there is an amount of loss incurred in a business year preceding each of those business years, the phrase "beginning within 10 years" in that paragraph is deemed to be replaced with "beginning".

②Where the provisions of Article 57, paragraph (1) of the Corporation Tax Act apply in each business year beginning on or before March 31, 2036 of the Banks' Shareholdings Purchase Corporation filing a blue return, if there is an amount of loss incurred in a business year preceding each of those business years, the phrase "the amount equivalent to 50 percent of the amount of income" in the proviso to that paragraph is deemed to be replaced with "the amount of income".

③The provisions of the preceding two paragraphs apply only where the Banks' Shareholdings Purchase Corporation has attached a written statement concerning the calculation of the amount of loss to the final return prescribed in Article 2, item (xxxi) of the Corporation Tax Act that is a blue return for the business year in which the amount of loss prescribed in those provisions arose, and has continuously filed final returns prescribed in that item for each subsequent business year.

①The provisions of Article 80, paragraph (1) and Article 144-13, paragraphs (1) and (2) of the Corporation Tax Act do not apply to the amount of loss incurred in each business year ending during the period from April 1, 1992 to March 31, 2028 of a corporation other than the corporations listed below; provided, however, that this does not apply to the amount of loss incurred in a business year ending during liquidation (excluding, of the business years ending during the liquidation of a group tax sharing subsidiary corporation, one ending on the day of the end of the business year of the group tax sharing parent corporation pertaining to that group tax sharing subsidiary corporation) and in a business year prescribed in Article 80, paragraph (4) or Article 144-13, paragraph (9) or (10) of that Act in a case falling under those provisions, the amount of deficit from disaster losses prescribed in Article 80, paragraph (5) or Article 144-13, paragraph (11) of that Act, and the amount of loss of the Banks' Shareholdings Purchase Corporation.

②Where, in a business year of a group tax sharing corporation prescribed in the main clause of the preceding paragraph, the group tax sharing corporation falls under the category of a cooperative, etc., or an amount of loss prescribed in the proviso to that paragraph (excluding the amount of deficit from disaster losses prescribed in the proviso to that paragraph; hereinafter referred to as the "deficit eligible for a refund" in this paragraph) has arisen, if another group tax sharing corporation that has a group tax sharing full controlling interest with that group tax sharing corporation at the end of that business year is a large group tax sharing corporation, then, with regard to the application of the provisions of Article 80, paragraph (7) of the Corporation Tax Act for that business year of the group tax sharing corporation and for the business year of the other group tax sharing corporation ending on that day, the amount of income prescribed in items (iii) and (iv) of that paragraph of the other group tax sharing corporation (excluding one in which a deficit eligible for a refund arose in that business year) is deemed to be nil.

①Where a corporation filing a blue return that is specified by Order of the Ministry of Finance as one that conducts, jointly with a new business developer (meaning a new business developer prescribed in Article 2, paragraph (6) of the Act on Strengthening Industrial Competitiveness; hereinafter the same applies in this paragraph), a specified business activity (meaning a specified business activity prescribed in paragraph (28) of that Article; hereinafter the same applies in this paragraph and paragraph (9)) (hereinafter referred to as a "covered corporation" in this paragraph and paragraph (15)) has acquired, within the designated period in each business year that includes a day within the period from April 1, 2020 to March 31, 2028 (hereinafter referred to as the "designated period" in this paragraph) (excluding a business year that includes the date of dissolution, each business year during liquidation, and a business year that includes the day before the date of a merger (excluding a qualified merger) of a merged corporation), specified shares (meaning, of the shares of a special new business development operator (meaning a corporation specified by Order of the Ministry of Finance as a new business developer that conducts a business contributing to a specified business activity; hereinafter the same applies in this paragraph), those specified by Cabinet Order as satisfying requirements including that they fall under any of the shares listed below; hereinafter the same applies in this Article), and continues to hold them until the end of the business year that includes the date of the acquisition (hereinafter referred to as the "covered business year" in this Article), then, if the covered corporation has accounted for an amount not exceeding the amount equivalent to 25 percent (where the specified shares fall under the shares listed in item (iii), 20 percent) of the acquisition price of the specified shares (where the acquisition price exceeds 20 billion yen (where the specified shares fall under the shares listed in item (i), 5 billion yen), 20 billion yen (where the specified shares fall under the shares listed in that item, 5 billion yen)) (where the book value of the specified shares has been reduced in the covered business year, the amount after deducting, from that equivalent amount, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of the amount so reduced that pertains to the amount included in deductible expenses in calculating the amount of income for the covered business year), by the method of setting up a special account for each special new business development operator and for each class of shares listed in the following items in the settlement of accounts finalized for the covered business year (including the method of setting it aside as a reserve through the appropriation of surplus by the day on which the settlement of accounts for the covered business year is finalized), an amount equivalent to the amount so accounted for is included in deductible expenses in calculating the amount of income for the covered business year. In this case, if that equivalent amount exceeds the amount calculated pursuant to the provisions of Cabinet Order as the amount of income for the covered business year (where the amount so calculated exceeds 12.5 billion yen, 12.5 billion yen; hereinafter referred to as the "income-based limit" in this paragraph), the amount to be included in deductible expenses is limited to the income-based limit.

②Where a corporation has carried out a qualified merger or a qualified company split, etc. (meaning a qualified company split or a qualified capital contribution in kind; hereinafter the same applies in this Article), the amount of the special account specified in each of the following items according to the category of qualified merger or qualified company split, etc. listed in that item is to be succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pertaining to that qualified merger or qualified company split, etc.:

③The provisions of the preceding paragraph apply, in the case of a corporation that has set up the special account referred to in paragraph (1) and has carried out a qualified company split, etc., only where the corporation that has set up the special account submits, within two months after the date of the qualified company split, etc., a document stating the amount of the special account to be passed on to the successor corporation in a company split or the corporation receiving a capital contribution in kind through the qualified company split, etc. and other matters specified by Order of the Ministry of Finance to the district director having jurisdiction over its place for tax payment.

④The amount of the special account succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (2) is deemed to be the amount of the special account set up by that merging corporation, successor corporation in a company split or corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (1).

⑤In the case referred to in the preceding paragraph, if the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind referred to in that paragraph is not a person that may file the final return, etc. for the business year that includes the date of the qualified merger or qualified company split, etc. as a blue return, the amount of the special account at the end of that business year is included in gross profit in calculating the amount of income for that business year.

⑥Where a corporation that has set up the special account referred to in paragraph (1) has had the approval for filing blue returns revoked, or has submitted a written notification to the effect that it will discontinue filing returns by blue return, the amount of the special account as of the day on which the fact that gave rise to the revocation of the approval occurred (where it falls under any of the cases listed in the following items, the day specified in that item) or the day on which the written notification was submitted (where the day on which the written notification was submitted is after the end of the business year in which it discontinued filing returns by blue return, the end of that business year) is included in gross profit in calculating the amount of income for the business year that includes that day. In this case, the provisions of paragraph (2), the following paragraph, paragraph (8), paragraphs (10) through (13) and paragraph (17) do not apply.

⑦Where a corporation that has set up the special account referred to in paragraph (1) has carried out a non-qualified share exchange, etc. prescribed in Article 62-9, paragraph (1) of the Corporation Tax Act in which it is the wholly owned subsidiary corporation in a share exchange, etc. or the wholly owned subsidiary corporation in a share transfer (hereinafter referred to as a "non-qualified share exchange, etc." in this paragraph), if the corporation holds an amount of the special account (excluding an amount less than the amount specified by Cabinet Order) at the time immediately before the non-qualified share exchange, etc., the amount of that special account is included in gross profit in calculating the amount of income for the business year that includes the date of the non-qualified share exchange, etc.

⑧Where a corporation that has set up the special account referred to in paragraph (1) has come to fall under the category of a domestic corporation prescribed in Article 64-11, paragraph (1) of the Corporation Tax Act, another domestic corporation prescribed in Article 64-12, paragraph (1) of that Act, or a group tax sharing corporation prescribed in Article 64-13, paragraph (1) of that Act (limited to one that satisfies the requirement listed in item (i) of that paragraph), if the corporation holds an amount of the special account (excluding an amount less than the amount specified by Cabinet Order) at the end of the business year immediately before the start of group tax sharing prescribed in Article 64-11, paragraph (1) of that Act, the business year immediately before joining group tax sharing prescribed in Article 64-12, paragraph (1) of that Act, or the business year immediately before the end of group tax sharing prescribed in Article 64-13, paragraph (1) of that Act, the amount of that special account is included in gross profit in calculating the amount of income for that business year immediately before the start of group tax sharing, business year immediately before joining group tax sharing or business year immediately before the end of group tax sharing.

⑨Where, for any business year of a corporation that has set up the special account referred to in paragraph (1), the case does not fall under the case specified by Order of the Ministry of Finance as a case where it has been made clear, through an investigation based on the provisions of Article 46, item (ii) of the Act on Strengthening Industrial Competitiveness or by other means, that a specified business activity is being conducted jointly with the corporation that issued the specified shares pertaining to that special account (excluding specified shares pertaining to the amount of a special account that is to be succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (2); hereinafter the same applies in this paragraph), the amount of the special account pertaining to those specified shares is included in gross profit in calculating the amount of income for that business year. In this case, the provisions of the preceding three paragraphs, the following paragraph, paragraph (11) and paragraph (17) do not apply.

⑩Where, at the end of any business year of a corporation that has set up the special account referred to in paragraph (1) (hereinafter referred to as a "corporation with the special account" in this paragraph), the amount of the special account pertaining to specified shares (excluding specified shares from a capital increase) carried over from the preceding business year includes an amount with respect to which any of the facts listed in the following items has occurred (hereinafter referred to as the "amount of the special account after five years, etc." in this paragraph) (excluding the case specified by Order of the Ministry of Finance as a case where it has been made clear, through an investigation based on the provisions of Article 46, item (ii) of the Act on Strengthening Industrial Competitiveness or by other means, that growth and development of the business of the corporation that issued those specified shares has been achieved for each business year of the corporation with the special account up to and including the business year that includes the day specified in the respective item according to the category of fact listed in that item), the amount of the special account after five years, etc. is included in gross profit in calculating the amount of income for the business year of the corporation with the special account that includes the day specified in the respective item according to the category of fact listed in that item. In this case, the provisions of paragraphs (7), (8) and (17) do not apply.

⑪Where, at the end of any business year of a corporation that has set up the special account referred to in paragraph (1) (hereinafter referred to as a "corporation with the special account" in this paragraph), the amount of the special account pertaining to specified shares (limited to those that fall under the shares listed in paragraph (1), item (iii)) carried over from the preceding business year includes an amount pertaining to specified shares for which the day on which three years have elapsed from the date of their acquisition has arrived (hereinafter referred to as the "amount of the special account after three years" in this paragraph) (excluding the case specified by Order of the Ministry of Finance as a case where it has been made clear, through an investigation based on the provisions of Article 46, item (ii) of the Act on Strengthening Industrial Competitiveness or by other means, that voting rights exceeding 50 percent of the voting rights of all shareholders of the corporation that issued those specified shares came to be held by that day), the amount of the special account after three years is included in gross profit in calculating the amount of income for the business year of the corporation with the special account that includes that day. In this case, the provisions of paragraphs (7), (8) and (17) do not apply.

⑫Where, at the end of any business year (hereinafter referred to as the "specified business year" in this paragraph) of a corporation that has set up the special account referred to in paragraph (1) (hereinafter referred to as a "corporation with the special account" in this paragraph), the amount of the special account pertaining to specified shares (excluding specified shares from a capital increase) carried over from the preceding business year includes an amount pertaining to a corporation that issued those specified shares and was dissolved through a merger, carried out before the specified business year, in which the corporation with the special account is the merging corporation (limited to the case specified by Order of the Ministry of Finance as a case where it has been made clear, through an investigation based on the provisions of Article 46, item (ii) of the Act on Strengthening Industrial Competitiveness or by other means, that growth and development of the business of the corporation that issued those specified shares has been achieved for each business year of the corporation with the special account up to and including the business year that includes the date of that merger (hereinafter referred to as the "merger business year" in this paragraph)), then, with regard to that amount of the special account, an amount equivalent to the amount calculated by multiplying the amount of that special account at the end of the merger business year by the number of months in the specified business year and dividing the result by 60 (where the amount so calculated exceeds the amount of that special account at the end of the specified business year, the amount of that special account) is included in gross profit in calculating the amount of income for the specified business year. In this case, the provisions of paragraph (2) and the preceding three paragraphs do not apply.

⑬Where a corporation that has set up the special account referred to in paragraph (1) (hereinafter referred to as a "corporation with the special account" in this paragraph) has come to fall under any of the cases listed in the following items (excluding where that special account is to be succeeded to by the merging corporation (limited to one that receives the transfer of the specified shares pertaining to that special account through a qualified merger), the successor corporation in a company split or the corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (2), and where the provisions of paragraph (9) have been applied with regard to that special account), the amount specified in each of those items, out of the amount of the special account, is included in gross profit in calculating the amount of income for the business year that includes the day on which it has come to fall under that case (in the case listed in item (ii), the business year that includes the day before the date of the merger):

⑭The provisions specified in each of the following items do not apply to the amount of the special account listed in that item:

⑮Where the provisions of paragraph (1) are applied for any covered business year of a group tax sharing corporation that is a covered corporation (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 income-based limit prescribed in that paragraph for that covered business year of that group tax sharing corporation is the amount equivalent to the pre-adjustment group tax sharing income-based limit (meaning the amount calculated pursuant to the provisions of 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 amounts specified by Cabinet Order as the income before group tax sharing and the deficit before group tax sharing prescribed in Article 64-5, paragraph (1) of that Act (referred to as the "income before group tax sharing" and the "deficit before group tax sharing", respectively, in the following paragraph) for that covered business year, or for the business year ending on the day of the end of that covered business year (referred to as the "other business year" in the following paragraph), 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 at the end of that covered business year; the same applies in the following paragraph)) (where that amount exceeds 12.5 billion yen, 12.5 billion yen).

⑯In the case referred to in the preceding paragraph, where the income before group tax sharing or the deficit before group tax sharing for the other business year of another group tax sharing corporation differs from the initially reported income before group tax sharing or the initially reported pre-aggregation loss amount (meaning, respectively, the amount stated, in the document attached to the final return, etc. (excluding a return filed after the due date) for the other business year of the other group tax sharing corporation, as the income before group tax sharing or the deficit before group tax sharing for that other business year of that other group tax sharing corporation; hereinafter the same applies in this paragraph), the initially reported income before group tax sharing or the initially reported pre-aggregation loss amount is deemed to be the income before group tax sharing or the deficit before group tax sharing for the other business year of the other group tax sharing corporation.

⑰If, at the end of each business year (hereinafter referred to as an "adjustment business year" in this paragraph) following the business year for which the provisions of paragraph (1) have been applied to a domestic corporation (limited to one ending on the day of the end of the business year of the group tax sharing parent corporation pertaining to the domestic corporation; hereinafter referred to as the "business year of application" in this paragraph), the deficit before group tax sharing prescribed in Article 64-5, paragraph (1) of the Corporation Tax Act (excluding that deemed not to exist pursuant to the provisions of Article 64-6 of that Act; hereinafter referred to as the "deficit before group tax sharing" in this paragraph and paragraph (19)) incurred in the business year ending on the base date (hereinafter referred to as the "other applicable business year" in this paragraph) of any of the other group tax sharing corporations (meaning other domestic corporations that have a group tax sharing full controlling interest with the domestic corporation as of the day of the end of the business year of application of the domestic corporation (hereinafter referred to as the "base date" in this paragraph); hereinafter the same applies in this paragraph) exceeds the amount stated as the deficit before group tax sharing in the document attached to the final return, etc. for that other applicable business year of that other group tax sharing corporation (limited to the case where the amount of that excess (hereinafter referred to as the "group tax sharing deficit shortfall amount" in this paragraph) includes an amount based on accounting that disguised facts; hereinafter referred to as the "case of an excessive return" in this paragraph), or if there is an amount stated as the deficit before group tax sharing in the document attached to the final return, etc. (limited to a return filed after the due date) for the other applicable business year of any of the other group tax sharing corporations (hereinafter referred to as the "amount of loss stated in a late return" in this paragraph) (hereinafter referred to as the "case of a loss stated in a late return" in this paragraph), and there is an amount, out of the amount of the special account at the end of that adjustment business year pertaining to the amount included in deductible expenses pursuant to the provisions of paragraph (1) in that business year of application, up to the amount obtained by deducting the pre-adjustment group tax sharing income-based shortfall (meaning, where the amount so included in deductible expenses is less than the pre-adjustment group tax sharing income-based limit prescribed in paragraph (15) for that business year of application, the amount of the shortfall) from the amount calculated by multiplying the amount listed in item (i) by the ratio listed in item (ii) (where there is an amount included in gross profit pursuant to the provisions of this paragraph in a business year preceding the adjustment business year with regard to the amount so obtained, the amount obtained by deducting the total of the amounts so included) (hereinafter referred to as the "amount to be added as an adjustment" in this paragraph), the amount to be added as an adjustment is included in gross profit in calculating the amount of income for the adjustment business year.

⑱The number of months referred to in paragraph (12) is calculated in accordance with the calendar, and a fraction of less than one month is counted as one month.

⑲In the application of the provisions of paragraph (17) for the adjustment business year prescribed in that paragraph of the domestic corporation referred to in that paragraph, where the deficit before group tax sharing incurred in the other applicable business year prescribed in that paragraph of a group tax sharing corporation with a triggering event prescribed in item (i) of that paragraph differs from the finalized amount of deficit before group tax sharing (meaning the amount stated as the deficit before group tax sharing in the most recent of the documents attached to the final return, etc. or amended return for that other applicable business year filed on or before the day of the end of that adjustment business year, or of the documents attached to the written notice of reassessment prescribed in Article 28, paragraph (2) of the Act on General Rules for National Taxes pertaining to a reassessment under the provisions of Article 24 or Article 26 of that Act made on or before that day; hereinafter the same applies in this paragraph), the finalized amount of deficit before group tax sharing is deemed to be the deficit before group tax sharing incurred in that other applicable business year.

⑳Where the provisions of Article 64-5, paragraph (8) of the Corporation Tax Act apply in the covered business year of the group tax sharing corporation referred to in paragraph (15), the provisions of paragraph (16) do not apply to that covered business year. In this case, the provisions of paragraph (17) and the preceding paragraph are not to apply to the adjustment business year prescribed in paragraph (17) of the domestic corporation referred to in that paragraph for which that covered business year is the business year of application prescribed in that paragraph.

（二十一）The provisions of paragraph (1) apply only if the final return, etc. 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 other documents specified by Order of the Ministry of Finance.

（二十二）The provisions of paragraph (1) do not apply to specified shares to which the provisions of Article 55, paragraph (1) or Article 56, paragraph (1) have been applied.

（二十三）With regard to the application of the provisions of Article 67, paragraphs (3) and (5) of the Corporation Tax Act, the amount included in deductible expenses pursuant to the provisions of paragraph (1) of a corporation to which the provisions of that paragraph have been applied (limited to the amount of the portion pertaining to specified shares from a capital increase) is to be included in the amount of income, etc. prescribed in those provisions, and, with regard to the application of the provisions of paragraphs (3) and (5) of that Article, the amount included in gross profit pursuant to the provisions of paragraphs (5) through (8), paragraph (13) or paragraph (17) (limited to the amount of the portion pertaining to specified shares from a capital increase) is not to be included in the amount of income, etc. prescribed in those provisions.

（二十四）Beyond what is provided for in the preceding three paragraphs, the calculation of the amount of revenue reserves of a corporation to which the provisions of paragraph (1), paragraphs (5) through (9), paragraph (13) or paragraph (17) have been applied and other necessary matters concerning the application of the provisions of paragraphs (1) through (20) are specified by Cabinet Order.

②With regard to the application of the provisions of the preceding paragraph in the case where the medical care corporation referred to in that paragraph calculates the amount listed in Article 72, paragraph (1), item (i) of the Corporation Tax Act, the phrase "50,000,000 yen" in that paragraph is deemed to be replaced with "25,000,000 yen", the phrase "70,000,000 yen" is deemed to be replaced with "35,000,000 yen", the phrase "25,000,000 yen" is deemed to be replaced with "12,500,000 yen", the phrase "30,000,000 yen" is deemed to be replaced with "15,000,000 yen", and the phrase "40,000,000 yen" is deemed to be replaced with "20,000,000 yen".

③The provisions of paragraph (1) do not apply if the final return, etc. does not contain a statement concerning the inclusion in deductible expenses of the expenses prescribed in that paragraph.

④Even where a final return, etc. without the statement referred to in the preceding paragraph has been filed, the district director may, when the district director finds that there were unavoidable circumstances for the absence of the statement, apply the provisions of paragraph (1), only if a document containing that statement is submitted.

①With regard to the income for each business year ending after the receipt of the approval of a medical care corporation that is a foundation, or a medical care corporation that is an association and has no provisions on equity interests (excluding one in liquidation), that has received the approval of the Commissioner of the National Tax Agency, pursuant to the provisions of Cabinet Order, as one that satisfies the requirements specified by Cabinet Order regarding its business significantly contributing to the spread and improvement of medical care, contribution to social welfare or other promotion of public interest and its being publicly operated (excluding a social medical care corporation prescribed in Article 42-2, paragraph (1) of the Medical Care Act), corporation tax is imposed at a tax rate of 19 percent, notwithstanding the provisions of Article 66, paragraphs (1), (2) and (6) of the Corporation Tax Act.

②Where it is found that a medical care corporation that has received the approval referred to in the preceding paragraph has ceased to satisfy the requirements specified by Cabinet Order prescribed in that paragraph, the Commissioner of the National Tax Agency is to revoke that approval retroactively to the time when it is found to have ceased to satisfy them. In this case, the provisions of that paragraph do not apply to the income for each business year of that medical care corporation ending on or after the time when it is found to have ceased to satisfy them.

③When the Commissioner of the National Tax Agency has granted the approval referred to in paragraph (1), has decided not to grant that approval, or has revoked that approval, the Commissioner must notify the medical care corporation that applied for the approval or the medical care corporation that had received the approval to that effect.

④Where the provisions of paragraph (1) apply, with regard to the application of the provisions of Article 69, paragraph (1) of the Corporation Tax Act, the phrase "Article 66, paragraphs (1) through (3) (Tax Rate of Corporation Tax on Income for Each Business Year)" in that paragraph is deemed to be replaced with "Article 67-2, paragraph (1) (Special Provisions on the Corporation Tax Rate for Specified Medical Care Corporations) of the Act on Special Measures Concerning Taxation"; with regard to the application of the provisions of paragraph (14) of that Article, the phrase "Article 66, paragraphs (1), (3) and (6)" in that paragraph is deemed to be replaced with "Article 67-2, paragraph (1) of the Act on Special Measures Concerning Taxation", and the phrase "paragraph (1) of that Article" is deemed to be replaced with "Article 66, paragraph (1)"; with regard to the application of the provisions of paragraph (19) of that Article (including as applied mutatis mutandis pursuant to paragraph (23) or paragraph (24) of that Article), the phrase "Article 66, paragraphs (1) through (3) and (6)" in paragraph (19) of that Article is deemed to be replaced with "Article 67-2, paragraph (1) of the Act on Special Measures Concerning Taxation", and the phrase "these" is deemed to be replaced with "that paragraph"; and with regard to the application of the provisions of Article 72, paragraph (1) or Article 74, paragraph (1) of that Act, the phrase "the preceding Section (Calculation of Tax Amount)" in Article 72, paragraph (1), item (ii) or Article 74, paragraph (1), item (ii) of that Act is deemed to be replaced with "Article 67-2, paragraph (1) (Special Provisions on the Corporation Tax Rate for Specified Medical Care Corporations) of the Act on Special Measures Concerning Taxation and Subsection 2 (Tax Credits) of the preceding Section".

⑤Beyond what is provided for in paragraphs (2) and (3), the procedures in the case where a corporation that has received the approval referred to in paragraph (1) intends to cease receiving the application of the provisions of that paragraph with regard to the income for each business year ending after the receipt of that approval, and other necessary matters concerning the application of the provisions of that paragraph and the preceding paragraph, are specified by Cabinet Order.

①Where a qualified farmland-owning corporation prescribed in Article 2, paragraph (3) of the Cropland Act has sold, in any business year that includes a day within the period from April 1, 1981 to March 31, 2030, within that period, the beef cattle prescribed in each of the following items by the method of sale listed in that item, if the beef cattle sold include tax-exempt raised cattle (meaning beef cattle that fall under beef cattle registered by a registration specified by Cabinet Order based on the registration rules prescribed in Article 32-9, paragraph (1) of the Act on Improvement and Increased Production of Livestock that have been approved by the Minister of Agriculture, Forestry and Fisheries pursuant to the provisions of that paragraph, or beef cattle whose sale price is less than 1,000,000 yen (or less than 800,000 yen where the beef cattle sold fall under the category of crossbred cattle specified by Order of the Ministry of Finance, and less than 500,000 yen where they fall under the category of dairy cattle specified by Order of the Ministry of Finance); hereinafter the same applies in this Article), an amount equivalent to the amount of profit from that sale of the tax-exempt raised cattle of the qualified farmland-owning corporation (where the total number of head of beef cattle that fall under tax-exempt raised cattle in the business year that includes the day of the sale exceeds 1,500, excluding the amount of profit from the sale of the portion exceeding 1,500 head) is included in deductible expenses in calculating the amount of income for the business year that includes the day of the sale.

②The beef cattle prescribed in the preceding paragraph means cattle other than the following cattle:

③The provisions of paragraph (1) apply only if the final return, etc. 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 a document certifying that the sale of the tax-exempt raised cattle was made by a method of sale listed in the items of that paragraph, the sale price, and any other matters specified by Order of the Ministry of Finance. In this case, the amount to be included in deductible expenses pursuant to the provisions of that paragraph is to be limited to the amount that should be included in deductible expenses as stated in that statement.

④Even where a final return, etc. without the statement or attachment referred to in the preceding paragraph has been filed, the district director may, when the district director finds that there were unavoidable circumstances for the absence of the statement or attachment, apply the provisions of paragraph (1), only if a document containing that statement, and the written statement and the certifying document referred to in that paragraph, are submitted.

⑤With regard to the application of the provisions of paragraph (1) to a qualified farmland-owning corporation referred to in that paragraph whose business year is less than one year, the phrase "exceeds 1,500" in that paragraph is deemed to be replaced with "exceeds the number of head calculated by multiplying 1,500 head by the number of months in that business year and dividing the result by 12", and the phrase "the portion exceeding 1,500 head" is deemed to be replaced with "the portion exceeding the number of head so calculated".

⑥The number of months referred to in the preceding paragraph is calculated in accordance with the calendar, and a fraction of less than one month is counted as one month.

⑦With regard to the application of the provisions of Article 67, paragraphs (3) and (5) of the Corporation Tax Act, the amount included in deductible expenses pursuant to the provisions of paragraph (1) of a qualified farmland-owning corporation referred to in that paragraph to which the provisions of that paragraph have been applied is to be included in the amount of income, etc. prescribed in those provisions.

⑧Beyond what is provided for in paragraph (2) through the preceding paragraph, the method of calculating the amount of profit from the sale of tax-exempt raised cattle, the calculation of the amount of revenue reserves of a qualified farmland-owning corporation referred to in paragraph (1) to which the provisions of that paragraph have been applied, and other necessary matters concerning the application of the provisions of that paragraph are specified by Cabinet Order.

①Where a corporation that, following the enactment of laws and regulations, the conclusion of a treaty or other international agreement, or any other act specified by Cabinet Order as equivalent thereto (referred to in this paragraph as the "enactment of laws and regulations, etc.") with regard to the consolidation of businesses or other restrictions on business activities, is required to close or convert the business that it operates (referred to in this Article as an "operator closing its business, etc.") has received, as a result of closing or converting that business, subsidies of the State or a local government (including those equivalent thereto) or compensation contributed by remaining business operators, etc. (meaning persons operating a business of the same type as that business who continue to operate that business even after the enactment of laws and regulations, etc., and organizations formed by them), which are specified by Cabinet Order (referred to in this Article as "business closure or conversion subsidies, etc.") (including the case where it has received them through an organization to which the operator closing its business, etc. belongs or any other person in accordance with the purpose of the grant of the business closure or conversion subsidies, etc.; the same applies hereinafter in this Article), if, in the business year that includes the day on which it received them, it has reduced, by accounting as an expense or loss and within the limit of an amount equivalent to the amount of the part of those business closure or conversion subsidies, etc. corresponding to what is specified by Cabinet Order as expenses for compensating for the depreciation of machinery and other depreciable assets pertaining to that business held by the corporation (referred to in this paragraph as a "grant compensating for depreciation"), the book value of the machinery or other depreciable assets pertaining to that grant compensating for depreciation, an amount equivalent to the amount so reduced is included in deductible expenses in calculating the amount of income for that business year.

②Where a corporation that is an operator closing its business, etc. has received business closure or conversion subsidies, etc., if, in the business year that includes the day on which it received them, it has made an acquisition (excluding an acquisition through a lease transaction without transfer of ownership, and including construction and manufacture; the same applies hereinafter in this Article) or improvement of fixed assets with an amount equivalent to all or part of the amount of the part of those business closure or conversion subsidies, etc. corresponding to what is specified by Cabinet Order as expenses for subsidizing the closure or conversion of the business that it operates (referred to in this Article as a "business closure or conversion subsidy"), and, with regard to those fixed assets, has reduced their book value by accounting as an expense or loss within the limit of an amount equivalent to the amount of the business closure or conversion subsidy spent on the acquisition or improvement (referred to in this paragraph as the "reduction entry limit"), or, instead of reducing their book value, has accounted for an amount not exceeding the reduction entry limit by the method of setting it aside as a reserve in the settlement of accounts finalized for that business year (including the method of setting it aside as a reserve through the appropriation of surplus by the day on which the settlement of accounts for that business year is finalized), an amount equivalent to the amount so reduced or accounted for is included in deductible expenses in calculating the amount of income for that business year.

③Where a corporation that is an operator closing its business, etc. receives business closure or conversion subsidies, etc. and, in the business year that includes the day on which it received them, carries out a qualified company split, a qualified capital contribution in kind or a qualified in-kind distribution (limited to one carried out on or after that day; hereinafter referred to as a "qualified company split, etc." in this paragraph, paragraph (10) and paragraph (17)), if, within the period from the beginning of that business year to the time immediately before the qualified company split, etc., it makes an acquisition or improvement of fixed assets with the amount of the business closure or conversion subsidy (limited to that received within that period) out of the amount of those business closure or conversion subsidies, etc., and transfers those fixed assets to the successor corporation in a company split, the corporation receiving a capital contribution in kind or the corporation receiving a distribution in kind through the qualified company split, etc., then, only where it has reduced the book value of those fixed assets within the limit of an amount equivalent to the business closure or conversion subsidy spent on the acquisition or improvement, an amount equivalent to the amount so reduced is included in deductible expenses in calculating the amount of income for that business year.

④Where a corporation that is an operator closing its business, etc. has received business closure or conversion subsidies, etc., if it is expected to make an acquisition or improvement of fixed assets with an amount equivalent to all or part of the amount of the business closure or conversion subsidy (where, in the business year that includes the day on which it received them, it has made an acquisition or improvement of fixed assets with an amount equivalent to part of that amount, the amount after deducting the amount spent on that acquisition or improvement; hereinafter the same applies in this Article) out of the amount of those business closure or conversion subsidies, etc., within the period from the day following the end of the business year that includes the day on which it received them (excluding a business year that includes the date of dissolution and a business year that includes the day before the date of a merger (excluding a qualified merger) of a merged corporation) until the day on which two years have elapsed after the day of receipt (where there are unavoidable circumstances specified by Cabinet Order, such as that the period required for the construction of a factory, etc. normally exceeds two years, the period specified by Cabinet Order; hereinafter referred to as the "designated period" in this paragraph and paragraph (6), item (ii)) (including where, in the case where the corporation carries out a qualified merger in which it is the merged corporation, the merging corporation pertaining to that qualified merger is expected to make an acquisition or improvement of fixed assets with all or part of the amount of that business closure or conversion subsidy within the designated period, and other cases specified by Cabinet Order), then, only where it has accounted for an amount not exceeding the amount of that business closure or conversion subsidy that it intends to appropriate for the acquisition or improvement of fixed assets, by the method of setting up a special account in the settlement of accounts finalized for the business year that includes the day on which it received them (including the method of setting it aside as a reserve through the appropriation of surplus by the day on which the settlement of accounts for that business year is finalized), an amount equivalent to the amount so accounted for is included in deductible expenses in calculating the amount of income for that business year.

⑤Where a corporation that is an operator closing its business, etc. receives business closure or conversion subsidies, etc. and, in the business year that includes the day on which it received them, carries out a qualified company split or a qualified capital contribution in kind (limited to one carried out on or after that day; hereinafter referred to as a "qualified company split, etc." in this Article, except in paragraph (10) and paragraph (17)), if the successor corporation in a company split or the corporation receiving a capital contribution in kind pertaining to the qualified company split, etc. is expected to make an acquisition or improvement of fixed assets with an amount equivalent to all or part of the amount of the business closure or conversion subsidy out of the amount of those business closure or conversion subsidies, etc., within the period from the date of the qualified company split, etc. until the day on which two years have elapsed after the day of receipt (where there are unavoidable circumstances specified by Cabinet Order, such as that the period required for the construction of a factory, etc. normally exceeds two years, the period specified by Cabinet Order), then, only where the corporation has set up an account equivalent to the special account referred to in the preceding paragraph (hereinafter referred to as a "special account during the year" in this Article) within the limit of the amount of that business closure or conversion subsidy that the successor corporation in a company split or the corporation receiving a capital contribution in kind intends to appropriate for the acquisition or improvement of fixed assets, an amount equivalent to the amount of the special account during the year so set up is included in deductible expenses in calculating the amount of income for that business year.

⑥Where a corporation has carried out a qualified merger, a qualified company split or a qualified capital contribution in kind, the amount of the special account or the amount of the special account during the year specified in each of the following items according to the category of qualified merger, qualified company split or qualified capital contribution in kind listed in that item is to be succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pertaining to that qualified merger, qualified company split or qualified capital contribution in kind:

⑦The provisions of the preceding paragraph apply, in the case of a corporation that has set up the special account referred to in paragraph (4) and has carried out a qualified company split, etc. (excluding a corporation that has set up both that special account and a special account during the year and that passes on only the amount of the special account during the year to the successor corporation in a company split or the corporation receiving a capital contribution in kind through the qualified company split, etc.), only where the corporation that has set up the special account submits, within two months after the date of the qualified company split, etc., a document stating the amount of that special account to be passed on to the successor corporation in a company split or the corporation receiving a capital contribution in kind through the qualified company split, etc. and other matters specified by Order of the Ministry of Finance to the district director having jurisdiction over its place for tax payment.

⑧The amount of the special account or the amount of the special account during the year succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (6) is deemed to be the amount of the special account set up by that merging corporation, successor corporation in a company split or corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (4).

⑨The provisions of paragraph (2) apply mutatis mutandis where a corporation that has set up the special account referred to in paragraph (4) has made an acquisition or improvement of fixed assets, with an amount equivalent to all or part of the amount of the business closure or conversion subsidy, out of the amount of business closure or conversion subsidies, etc., that it intends to appropriate for the acquisition or improvement of fixed assets, within the designated period prescribed in that paragraph (where the amount of that special account is the amount of a special account during the year succeeded to pursuant to the provisions of paragraph (6), or in other cases specified by Cabinet Order, the period prescribed in paragraph (5) or any other period specified by Cabinet Order; hereinafter referred to as the "designated period" in this Article). In this case, the phrase "the settlement of accounts finalized for that business year" in paragraph (2) is deemed to be replaced with "the settlement of accounts finalized for the business year that includes the day on which the acquisition or improvement of those fixed assets was made".

⑩The provisions of paragraph (3) apply mutatis mutandis where a corporation that has set up the special account referred to in paragraph (4) carries out a qualified company split, etc., and the corporation has made an acquisition or improvement of fixed assets, with an amount equivalent to all or part of the amount of the business closure or conversion subsidy, out of the amount of business closure or conversion subsidies, etc., that it intends to appropriate for the acquisition or improvement of fixed assets, within the designated period of the business year that includes the date of the qualified company split, etc., and transfers those fixed assets to the successor corporation in a company split, the corporation receiving a capital contribution in kind or the corporation receiving a distribution in kind through the qualified company split, etc. In this case, the phrase "in calculating the amount of income for that business year" in paragraph (3) is deemed to be replaced with "in calculating the amount of income for the business year that includes the day on which the acquisition or improvement of those fixed assets was made".

⑪Where a corporation that has set up the special account referred to in paragraph (4) has come to fall under any of the cases listed in the following items (excluding where that special account is to be succeeded to by the merging corporation, the successor corporation in a company split or the corporation receiving a capital contribution in kind pursuant to the provisions of paragraph (6)), the amount specified in each of those items is included in gross profit in calculating the amount of income for the business year that includes the day on which it has come to fall under that case (in the case listed in item (v), the business year that includes the day before the date of the merger):

⑫The provisions listed in the items of Article 53, paragraph (1) do not apply to assets to which the provisions of paragraph (2) (including as applied mutatis mutandis pursuant to paragraph (9); the same applies in the following paragraph and paragraph (14)) or paragraph (3) (including as applied mutatis mutandis pursuant to paragraph (10); the same applies in the following paragraph and paragraph (14)) have been applied.

⑬Where the provisions of laws and regulations concerning corporation tax are applied to assets to which the provisions of paragraph (2) or paragraph (3) have been applied, the amount included in deductible expenses in calculating the amount of income for each business year pursuant to those provisions is not included in the acquisition price of those assets.

⑭Where a merging corporation, a successor corporation in a company split, a corporation receiving a capital contribution in kind or a corporation receiving a distribution in kind pertaining to a qualified merger, a qualified company split, a qualified capital contribution in kind or a qualified in-kind distribution (hereinafter referred to as a "qualified merger, etc." in this paragraph) that has received, through that qualified merger, etc., the transfer of fixed assets to which the provisions of paragraph (2) or paragraph (3) have been applied applies the provisions of laws and regulations concerning corporation tax to those fixed assets, the amount that was not included in the acquisition price of those fixed assets by the merged corporation, the splitting corporation, the corporation making a capital contribution in kind or the corporation making a distribution in kind pertaining to that qualified merger, etc. is not included in the acquisition price of those fixed assets.

⑮The provisions of paragraph (1), (2), (4) or (9) apply only if the final return, etc. contains a statement concerning the inclusion in deductible expenses of the amount to be included in deductible expenses pursuant to those provisions, and has attached to it a written statement concerning the calculation of the amount to be included in deductible expenses and other documents specified by Order of the Ministry of Finance.

⑯Even where a final return, etc. without the statement or attachment referred to in the preceding paragraph has been filed, the district director may, when the district director finds that there were unavoidable circumstances for the absence of the statement or attachment, apply the provisions of paragraph (1), (2), (4) or (9), only if a document containing that statement, and the written statement and the documents specified by Order of the Ministry of Finance referred to in that paragraph, are submitted.

⑰The provisions of paragraph (3) apply only where the corporation seeking the application of the provisions of that paragraph submits, within two months after the date of the qualified company split, etc., a document stating the amount reduced as prescribed in that paragraph and other matters specified by Order of the Ministry of Finance to the district director having jurisdiction over its place for tax payment. The same applies where the provisions of that paragraph are applied as read with the replacement of terms pursuant to the provisions of paragraph (10).

⑱The provisions of paragraph (5) apply only where the corporation seeking the application of the provisions of that paragraph submits, within two months after the date of the qualified company split, etc., a document stating the amount of the special account during the year and other matters specified by Order of the Ministry of Finance to the district director having jurisdiction over its place for tax payment.

⑲Matters necessary for the application of the provisions of paragraphs (1) through (11) and other matters necessary for the application of the provisions of the Corporation Tax Act with regard to business closure or conversion subsidies, etc. are specified by Cabinet Order.

①Where a small and medium sized enterprise, etc. (meaning a small and medium sized enterprise prescribed in Article 42-4, paragraph (19), item (vii) (excluding one that falls under an excluded business operator prescribed in item (viii) of that paragraph) or an agricultural cooperative, etc. prescribed in item (ix) of that paragraph that files a blue return (limited to one specified by Cabinet Order as one for which consideration needs to be given to the administrative burden, and excluding a group tax sharing corporation and, of those that fall under a specified business operator, etc. prescribed in Article 42-12-4, paragraph (1) that has received the specified certification prescribed in that paragraph, one whose specified management capacity improvement plan prescribed in that paragraph pertaining to that specified certification states the depreciable assets listed in item (ii) of that paragraph); hereinafter the same applies in this paragraph) holds depreciable assets that it has acquired, manufactured or constructed during the period from April 1, 2006 to March 31, 2029 and has used for the business of that small and medium sized enterprise, etc., and whose acquisition cost is less than 400,000 yen (excluding those whose acquisition cost is less than 100,000 yen, those that receive the application of the provisions listed in the items of Article 53, paragraph (1), and any other assets specified by Cabinet Order; hereinafter referred to as "low-value depreciable assets" in this Article), if it has carried out accounting as an expense or loss for an amount equivalent to the acquisition cost of those low-value depreciable assets in the business year that includes the day on which it used them for the business of that small and medium sized enterprise, etc., the amount for which it carried out that accounting as an expense or loss is included in deductible expenses in calculating the amount of income for that business year. In this case, where the total acquisition cost of low-value depreciable assets of that small and medium sized enterprise, etc. in that business year exceeds 3,000,000 yen (where that business year is less than one year, the amount calculated by dividing 3,000,000 yen by 12 and multiplying the result by the number of months in that business year; hereinafter the same applies in this paragraph), the amount included is limited to the total acquisition cost of the low-value depreciable assets up to 3,000,000 yen, out of that total acquisition cost.

②The number of months referred to in the preceding paragraph is calculated in accordance with the calendar, and a fraction of less than one month is counted as one month.

③The provisions of paragraph (1) apply only if a written statement concerning the acquisition cost of the low-value depreciable assets to which the provisions of that paragraph are applied is attached to the final return, etc.

④Where the provisions of laws and regulations concerning corporation tax are applied to low-value depreciable assets to which the provisions of paragraph (1) have been applied, the amount included in deductible expenses in calculating the amount of income for each business year pursuant to the provisions of that paragraph is not included in the acquisition cost of those low-value depreciable assets.

⑤Beyond what is provided for in the preceding three paragraphs, necessary matters concerning the application of the provisions of paragraph (1) are specified by Cabinet Order.

①Where there is an amount of distributions of proceeds of a specified stock investment trust prescribed in Article 3-2 (excluding a foreign stock price index-linked specified stock investment trust prescribed in Article 9, paragraph (1), item (iii)) received by a corporation, with regard to the application of the provisions of Article 23 of the Corporation Tax Act, the phrase "or distribution of surplus" in paragraph (1), item (i) of that Article is deemed to be replaced with ", distribution of surplus", the phrase "pertaining to contributions)" with "pertaining to contributions) or distributions of proceeds of a specified stock investment trust prescribed in Article 67-6, paragraph (1) (Special Provisions on Exclusion from Gross Profit of Dividends Received, etc. Pertaining to Distributions of Proceeds of Specified Stock Investment Trusts) of the Act on Special Measures Concerning Taxation (hereinafter referred to as a 'specified stock investment trust' in this Article)", the phrase "the shares, etc. that are the principal" in paragraph (2) of that Article with "the shares, etc. (including beneficial interests in a specified stock investment trust; hereinafter the same applies in this paragraph) that are the principal", the phrase "the date specified in each of the following items for the category of the amount of dividends, etc. listed in that item" with "the date specified in each of the following items for the category of the amount of dividends, etc. listed in that item and, for distributions of proceeds of a specified stock investment trust, the last day of the period that served as the basis for their calculation", and the phrase "prescribed in the preceding paragraph)" in paragraph (6) of that Article with "prescribed in the preceding paragraph) and beneficial interests in a specified stock investment trust".

②Cabinet Order provides for the necessary particulars concerning the application of the provisions of the preceding paragraph.

①Where, in any business year of a corporation filing a blue return that conducts insurance business under a license prescribed in Article 3, paragraph (1) or Article 185, paragraph (1) of the Insurance Business Act, there is an amount of dividends and similar income prescribed in Article 23, paragraph (1) of the Corporation Tax Act (including as applied with the replacement of terms pursuant to the provisions of paragraph (1) of the preceding Article) received with respect to non-controlling-purpose shares, etc. prescribed in paragraph (6) of that Article (including as applied with the replacement of terms pursuant to the provisions of paragraph (1) of the preceding Article) held by it (hereinafter referred to as the "amount of dividends and similar income on special non-controlling-purpose shares, etc." in this paragraph), the amount not included in gross profit in calculating the amount of income for each of those business years pursuant to the provisions of Article 23, paragraph (1) of that Act with regard to that amount of dividends and similar income on special non-controlling-purpose shares, etc. is, notwithstanding the provisions of that paragraph, the amount equivalent to 40 percent of that amount of dividends and similar income on special non-controlling-purpose shares, etc.

②Cabinet Order provides for the necessary particulars concerning the application of the provisions of the preceding paragraph.

①Where, in any business year of a cooperative, etc., there is an amount of dividends and similar income (meaning the amount of dividends and similar income prescribed in Article 23, paragraph (1) of the Corporation Tax Act) received with respect to contributions held by it to a federation, etc. (meaning the Norinchukin Bank or any other cooperative, etc. whose members or partners are limited, pursuant to the provisions of the governing laws listed in the right-hand column of Appended Table 3 of the Corporation Tax Act, to other cooperatives, etc. and corporations equivalent thereto) (excluding those that fall under preferred equity investments prescribed in the Act on Preferred Equity Investment by Cooperative Structured Financial Institution; hereinafter referred to as "ordinary contributions" in this paragraph), then, with regard to the application of the provisions of that Article, those ordinary contributions are deemed not to fall under any of the shares, etc. of related corporations, the shares, etc. of wholly owned subsidiary corporations and the non-controlling-purpose shares, etc. prescribed in paragraphs (4) through (6) of that Article, notwithstanding those provisions.

②Cabinet Order provides for the necessary particulars concerning the application of the provisions of the preceding paragraph.

①Where a corporation falls under the category of a specified partner (meaning, of partners under a partnership contract (including persons similar thereto who are specified by Cabinet Order, and, for a silent partnership contract, etc., meaning a person who makes a contribution based on the silent partnership contract, etc. and a person who succeeds to that person's status pertaining to that silent partnership contract, etc.; hereinafter the same applies in this paragraph and paragraph (4)), those other than a partner who is involved in decisions on the execution of business concerning the disposal or acquisition of important property pertaining to the partnership business or concerning large borrowings pertaining to the partnership business, and who personally executes the important parts of that business, such as negotiations for concluding contracts, or any other partner specified by Cabinet Order; the same applies in paragraph (4)) or a specified beneficiary (meaning a beneficiary prescribed in Article 12, paragraph (1) of the Corporation Tax Act (including a person deemed to be a beneficiary prescribed in paragraph (1) of that Article pursuant to the provisions of paragraph (2) of that Article) of a trust (excluding a collective investment trust prescribed in Article 2, item (xxix) of that Act and a trust subject to corporate taxation; hereinafter the same applies in this Article); the same applies in paragraph (4)), and where the limit of the liability to repay the debts of the partnership business under that partnership contract or of that trust is substantially the value of the partnership property (for a silent partnership contract, etc., the property pertaining to the partnership business) or of the trust property, or in any other case specified by Cabinet Order, an amount equivalent to the portion of the partnership loss, etc. of the corporation for that business year (meaning the amount specified by Cabinet Order as the amount of loss of the corporation from that partnership business or that trust; hereinafter the same applies in this paragraph) that exceeds the amount calculated pursuant to the provisions of Cabinet Order on the basis of the value of the contribution of the corporation pertaining to that partnership business or the book value of the trust property of that trust (where the case falls under the case specified by Cabinet Order as one in which the profits and losses attributed to that partnership business or that trust property are expected not to result substantially in a loss, that partnership loss, etc.) (referred to as the "excess partnership loss, etc." in paragraph (3), item (iv)) is not included in deductible expenses in calculating the amount of income for that business year.

②Where a corporation filing a final return, etc. has a total excess partnership loss, etc. in any business year, the amount of that total excess partnership loss, etc. up to the amount specified by Cabinet Order as the amount of profit of that corporation for that business year from the partnership business or trust (limited to one pertaining to that total excess partnership loss, etc.) is included in deductible expenses in calculating the amount of income for that business year.

③In this Article, the meanings of the terms listed in the following items are as prescribed respectively in those items:

④Beyond what is provided for in the preceding paragraph, matters concerning the application of the provisions of paragraph (1) in the case where a corporation has succeeded, through a qualified merger in which it is the merging corporation, to the status of a partner under a partnership contract or of a beneficiary of a trust of a merged corporation that falls under the category of a specified partner or a specified beneficiary, and other necessary matters concerning the application of the provisions of paragraph (1) or paragraph (2), are specified by Cabinet Order.

①Where the amount specified by Cabinet Order as the amount of loss from the partnership business (meaning the business carried on under that limited liability business partnership agreement; hereinafter the same applies in this Article) for that business year of a corporation that is a partner that has concluded a limited liability business partnership agreement prescribed in Article 3, paragraph (1) of the Limited Liability Partnership Act exceeds the amount calculated pursuant to the provisions of Cabinet Order on the basis of the value of the contribution of the corporation pertaining to that partnership business, an amount equivalent to the excess (referred to as the "excess partnership loss" in paragraph (3)) is not included in deductible expenses in calculating the amount of income for that business year.

②Where a corporation filing a final return, etc. has a total excess partnership loss in any business year, the amount of that total excess partnership loss up to the amount specified by Cabinet Order as the amount of profit of that corporation for that business year from the partnership business (limited to one pertaining to that total excess partnership loss) is included in deductible expenses in calculating the amount of income for that business year.

③The total excess partnership loss prescribed in the preceding paragraph means the amount obtained by totaling, for each partnership business, of the excess partnership losses in each business year up to and including the business year preceding that business year of that corporation, each excess partnership loss in the case where the corporation has continuously filed final returns prescribed in Article 2, item (xxxi) of the Corporation Tax Act (hereinafter referred to as a "final return" in this paragraph) from the business year for which the provisions of paragraph (1) were applied to that excess partnership loss (hereinafter referred to as the "applicable business year" in this paragraph) through the preceding business year (where the applicable business year is the preceding business year, in the case where it has filed the final return for that applicable business year) (where there is an amount included in deductible expenses in calculating the amount of income for any business year up to the preceding business year pursuant to the provisions of the preceding paragraph, the amount after deducting the amount so included).

④Beyond what is provided for in the preceding paragraph, matters concerning the application of the provisions of paragraph (1) in the case where a corporation has succeeded, through a qualified merger in which it is the merging corporation, to the status as a partner of a merged corporation that is a partner prescribed in that paragraph, and other necessary matters concerning the application of the provisions of paragraph (1) or paragraph (2), are specified by Cabinet Order.

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.

①The amount listed in Article 23, paragraph (1), item (ii) of the Corporation Tax Act (including, where the amount of money that an investment corporation delivers to its unitholders (meaning unitholders prescribed in Article 2, paragraph (16) of the Investment Corporation Act) due to any of the grounds listed in the items of Article 24, paragraph (1) of that Act (excluding items (ii), (iii) and (vii)) exceeds the amount specified by Cabinet Order as the amount of the portion, out of the amount of stated capital, etc. of that investment corporation prescribed in Article 2, item (xvi) of the Corporation Tax Act, that corresponds to the investment units of that investment corporation (meaning investment units prescribed in Article 2, paragraph (14) of the Investment Corporation Act; the same applies in item (i) and paragraph (7)) that gave rise to that delivery, the amount of the excess portion, and any other amount specified by Cabinet Order; referred to as the "amount of dividends and similar income" in this paragraph and paragraph (4)) paid by an investment corporation prescribed in Article 2, paragraph (12) of the Act on Investment Trusts and Investment Corporations (referred to as the "Investment Corporation Act" in this paragraph and the following paragraph) (limited to one that satisfies the requirements listed in item (i)), which pertains to a business year that satisfies the requirements listed in item (ii) (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 if that amount of dividends and similar income 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 that amount 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 an investment corporation, the phrase "falls under" in Article 62-3, paragraph (3) is deemed to be replaced with "falls under, and a transfer conducted by an investment corporation prescribed in Article 2, paragraph (12) of the Act on Investment Trusts and Investment Corporations that is conducted in a business year that satisfies the requirements listed in Article 67-15, paragraph (1), item (ii) (excluding (e))", the phrase "a foreign corporation (excluding one that falls under the category of 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" with "the Corporation Tax Act", the phrase "a foreign corporation (excluding one that falls under the category of 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 with "a foreign corporation", the phrase "a foreign corporation (excluding one that falls under the category of 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) with "a foreign corporation", the phrase "that Act" with "the Corporation Tax Act", and the phrase "a foreign corporation (excluding one that falls under the category of 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 with "a foreign corporation".

④With regard to the amount of dividends and similar income that a corporation receives from an investment corporation, the provisions of Article 23, paragraph (1) of the Corporation Tax Act do not apply.

⑤The provisions of paragraph (1) apply only where the investment corporation has filed a final return, etc. for the business year for which it seeks the application of the provisions of that paragraph, with an application made therein to seek the inclusion in deductible expenses of the amount to be included in deductible expenses pursuant to the provisions of that paragraph and a written statement attached thereto regarding the calculation of the amount to be included in deductible expenses, and has preserved the documents that certify that the requirements listed in item (i), (b) and (c) of that paragraph are satisfied.

⑥Even where the investment corporation has filed a final return, etc. without the application or written statement set forth in the preceding paragraph attached thereto or failed to preserve the documents on the calculation set forth in the paragraph, the district director may, when they find any unavoidable reason for the investment corporation's failure to make a necessary application, attach a necessary written statement or preserve the necessary documents on the calculation, apply the provisions of paragraph (1).

⑦Beyond what is provided for in the preceding two paragraphs, special provisions on the requirement listed in paragraph (1), item (ii), (g) for an investment corporation whose investment units are listed on a financial instruments exchange prescribed in Article 2, paragraph (16) of the Financial Instruments and Exchange Act or that satisfies other requirements, and other necessary matters concerning the application of the provisions of paragraphs (1) through (4) and of the provisions of laws and regulations concerning corporation tax with respect to investment corporations and their members, are specified by Cabinet Order.

①With regard to the domestic source income listed in Article 138, paragraph (1), item (i) of the Corporation Tax Act (excluding that which falls under the domestic source income listed in items (ii) through (vi) of that paragraph and the domestic source income listed in Article 161, paragraph (1), items (viii) through (xi) and items (xiii) through (xvi) of the Income Tax Act) held by a foreign corporation that is a partner who has concluded an investment partnership contract (meaning an investment partnership contract prescribed in Article 41-21, paragraph (4), item (i); hereinafter the same applies in this Article), that conducts business through a permanent establishment under that investment partnership contract and that satisfies the requirements listed in the items of Article 41-21, paragraph (1), which is attributable to that permanent establishment (referred to as "covered domestic source income" in the following paragraph), no corporation tax is imposed.

②If a foreign corporation has received the application of the provisions of the preceding paragraph with respect to covered domestic source income, the amount specified by Cabinet Order as the amount of loss pertaining to covered domestic source income arising from the business conducted through a permanent establishment under the investment partnership contract concluded by that foreign corporation to which that application pertains (referred to as a "special application partnership business" in the following paragraph) is deemed not to exist for the purpose of applying the provisions of the Corporation Tax Act and other laws and regulations concerning corporation tax.

③If the provisions of paragraph (1) apply, the domestic source income listed in Article 138, paragraph (1), item (i) of the Corporation Tax Act (limited to that which falls under the domestic source income listed in items (ii) through (vi) of that paragraph and the domestic source income listed in Article 161, paragraph (1), items (viii) through (xi) and items (xiii) through (xvi) of the Income Tax Act) held by a foreign corporation that is attributable to a permanent establishment pertaining to a special application partnership business is deemed not to fall under the domestic source income listed in Article 138, paragraph (1), item (i) of the Corporation Tax Act, and the provisions of that Act, this Act and other laws and regulations concerning corporation tax apply accordingly.

④The provisions of Article 41-21, paragraphs (5) through (13) apply mutatis mutandis to the case where the provisions of paragraph (1) apply. In this case, the phrase "the day before the date on which the domestic source income listed in Article 161, paragraph (1), item (iv) of the Income Tax Act received under the investment partnership contract pertaining to that special application return is deemed to have been paid under the provisions of Article 212, paragraph (5) of that Act (or, if the person is a nonresident, that day before or March 15 of the year following the year that includes the date on which the person first comes to have domestic source income prescribed in Article 161, paragraph (1) of that Act on or after the date on which the person came to fall under that case, whichever is earlier)" in paragraph (9) of that Article is deemed to be replaced with "the due date for filing the return under the provisions of Article 144-6, paragraph (1) of the Corporation Tax Act for the business year prescribed in Article 2, paragraph (2), item (xix) that includes the date on which the person comes to have domestic source income prescribed in Article 138, paragraph (1) of that Act".

⑤With regard to the application of the provisions of Article 146, paragraph (2), Article 146-2, paragraph (2) and Article 150-2 of the Corporation Tax Act in the case where the provisions of paragraph (1) apply, the term "internal dealings" in the row of Article 123, item (ii) (Dismissal of Application for Approval of Blue Return) in the table in Article 146, paragraph (2) of that Act, in Article 146-2, paragraph (2) and in Article 150-2, paragraph (1) is deemed to be replaced with "internal dealings (excluding those pertaining to covered domestic source income prescribed in Article 67-16, paragraph (1) (Special Provisions on Taxation on Foreign Partners) of the Act on Special Measures Concerning Taxation)".

⑥Beyond what is provided for in the preceding two paragraphs, necessary matters concerning the application of the provisions of paragraph (1) and the application of other provisions of laws and regulations concerning corporation tax with respect to foreign corporations that have concluded investment partnership contracts are specified by Cabinet Order.

①No corporation tax is imposed on the domestic source income listed in Article 138, paragraph (1), item (i) of the Corporation Tax Act, or the domestic source income listed in item (vi) of that paragraph that is specified by Cabinet Order, for each business year of the following foreign corporations (limited to such domestic source income pertaining to the Expo-related work prescribed in Article 29 performed during the period from April 1, 2025 to March 31, 2028; referred to as "covered domestic source income" in the following paragraph):

②The amount specified by Cabinet Order as the amount of loss pertaining to covered domestic source income for each business year of a foreign corporation listed in any of the items of the preceding paragraph is deemed not to exist for the purpose of applying the provisions of the Corporation Tax Act and other laws and regulations concerning corporation tax.

③With regard to the application of the provisions of Article 146-2, paragraph (2) and Article 150-2 of the Corporation Tax Act in the case where the provisions of paragraph (1) apply, the term "internal dealings" in that paragraph and in paragraph (1) of that Article is deemed to be replaced with "internal dealings (excluding those pertaining to covered domestic source income prescribed in Article 67-16-2, paragraph (1) (Special Provisions on Taxation on Foreign Corporations, etc. That Are Official Participants in the International Horticultural Expo 2027 to Be Held in 2027) of the Act on Special Measures Concerning Taxation)".

④Beyond what is provided for in the preceding paragraph, necessary matters concerning the application of the provisions of laws and regulations concerning corporation tax with respect to the foreign corporations listed in the items of paragraph (1) are specified by Cabinet Order.

①No corporation tax is imposed on profit from redemption (meaning the margin profit generated when the amount received from the redemption (including retirement by purchase; the same applies in the following paragraph, paragraph (3) and paragraph (11)) of the book-entry government bonds or book-entry municipal bonds exceeds the acquisition cost of the book-entry government bonds or book-entry municipal bonds) that a foreign corporation receives with respect to book-entry government bonds prescribed in Article 5-2, paragraph (1) (excluding those that fall under discount bonds (meaning discount bonds prescribed in Article 41-13, paragraph (1); hereinafter the same applies in this paragraph and the following paragraph); referred to as "book-entry government bonds" in this paragraph and paragraph (11)) or book-entry municipal bonds prescribed in Article 5-2, paragraph (1) (excluding those that fall under discount bonds; referred to as "book-entry municipal bonds" in this paragraph and paragraph (11)).

②No corporation tax is imposed on profit from redemption (meaning the margin profit generated when the amount received from the redemption of the specified book-entry corporate bonds, etc. exceeds the acquisition cost of the specified book-entry corporate bonds, etc.) that a foreign corporation receives with respect to specified book-entry corporate bonds, etc. prescribed in Article 5-3, paragraph (4), item (vii) (excluding those that fall under discount bonds; referred to as "specified book-entry corporate bonds, etc." in this paragraph, paragraph (11) and paragraph (13)), which is received by a person that is not a specially related person, prescribed in paragraph (2) of that Article, of the person issuing those specified book-entry corporate bonds, etc.

③No corporation tax is imposed on profit from redemption (meaning the margin profit generated when the amount received from the redemption of the private foreign bonds exceeds the acquisition cost of the private foreign bonds) that a foreign corporation receives with respect to private foreign bonds prescribed in Article 6, paragraph (4) issued on or after April 1, 1998 (referred to as "private foreign bonds" in this paragraph and paragraph (11)), which is received by a person that is not a specially related person, prescribed in paragraph (4) of that Article, of the person issuing those private foreign bonds.

④Out of the profit from redemption of discount bonds prescribed in Article 41-12-2, paragraph (6), item (i) issued by a foreign corporation (meaning the margin profit generated when the amount received from the redemption, prescribed in paragraph (1) of that Article, of those discount bonds exceeds the acquisition cost of those discount bonds), that which is specified by Cabinet Order as pertaining to the business conducted through the permanent establishment of that foreign corporation is deemed to be the domestic source income listed in Article 138, paragraph (1), item (ii) of the Corporation Tax Act, and the provisions of that Act and other laws and regulations concerning corporation tax apply accordingly.

⑤Profit from redemption prescribed in Article 41-12, paragraph (7) (excluding that which falls under the domestic source income listed in Article 141, item (i), (a) of the Corporation Tax Act) of discount bonds prescribed in paragraph (7) of that Article (limited to those to which the provisions of paragraph (3) of that Article have been applied) received by a foreign corporation is to be treated as not falling under the domestic source income listed in (b) of that item or in Article 141, item (ii) of that Act.

⑥Where a foreign corporation has income arising from the holding of specified book-entry discount bonds (meaning specified book-entry discount bonds prescribed in Article 41-13-3, paragraph (7), item (vii); hereinafter the same applies in this paragraph and paragraph (11)) for which it has received entries or records under the book-entry transfer system prescribed in item (vi) of that paragraph in its account established with a specified book-entry transfer institution, etc. (meaning a specified book-entry transfer institution, etc. prescribed in paragraph (1) of that Article; hereinafter the same applies in this paragraph) or a qualified foreign intermediary (meaning a qualified foreign intermediary prescribed in paragraph (7), item (iv) of that Article; hereinafter the same applies in this paragraph), via a business office or any other office of the specified book-entry transfer institution, etc. located in Japan or a specified overseas business office, etc. prescribed in paragraph (7), item (v) of that Article of the qualified foreign intermediary, corporation tax is not imposed with respect to the income arising from the holding of those specified book-entry discount bonds that arises for a person that is not a specially related person, prescribed in paragraph (4) of that Article, of the issuer of those specified book-entry discount bonds.

⑦No corporation tax is imposed on lending fees, etc. (meaning the margin specified by Cabinet Order as arising from a bond transaction with a repurchase/resale agreement prescribed in Article 42-2, paragraph (1) (referred to as a "bond transaction with a repurchase/resale agreement" in paragraph (9)), or the money paid as consideration for the lending of the securities listed in the items of paragraph (1) of that Article to a specified financial institution, etc. through a securities lending transaction prescribed in that paragraph; the same applies in the following paragraph) that a foreign financial institution, etc. prescribed in Article 42-2, paragraph (7), item (i) (referred to as a "foreign financial institution, etc." in the following paragraph) receives, with respect to a specified bond transaction with a repurchase/resale agreement, etc. involving book-entry bonds, etc. prescribed in paragraph (1) of that Article, from a specified financial institution, etc. prescribed in paragraph (7), item (ii) of that Article (referred to as a "specified financial institution, etc." in this paragraph and paragraph (9)).

⑧The provisions of Article 42-2, paragraph (2) apply mutatis mutandis to a foreign financial institution, etc. that receives lending fees, etc. In this case, in that paragraph, the phrase "the provisions of the preceding paragraph" is deemed to be replaced with "the provisions of Article 67-17, paragraph (7)", the phrase "and the preceding paragraph" with "and paragraph (7) of that Article", the phrase "that preceding paragraph" with "that paragraph (7) of that Article", the phrase "pertaining to the interest received" with "pertaining to lending fees, etc. (referred to as 'lending fees, etc.' in this paragraph)", the phrase "received by the foreign financial institution, etc. referred to in that paragraph" with "received by the foreign financial institution, etc. referred to in paragraph (7) of that Article", and the phrase "the interest received prescribed in that paragraph" with "lending fees, etc.", and the term "interest" in items (i) and (iii) of that paragraph is deemed to be replaced with "lending fees, etc.".

⑨No corporation tax is imposed on the margin specified by Cabinet Order as arising from a bond transaction with a repurchase/resale agreement that a specified foreign corporation prescribed in Article 42-2, paragraph (3) (referred to as a "specified foreign corporation" in the following paragraph) receives from a specified financial institution, etc. with respect to a specified bond transaction with a repurchase/resale agreement involving book-entry government bonds, etc. prescribed in paragraph (3) of that Article that commenced during the period from April 1, 2017 to March 31, 2029.

⑩The provisions of Article 42-2, paragraph (4) apply mutatis mutandis to a specified foreign corporation that receives the margin prescribed in the preceding paragraph. In this case, the phrase "the preceding paragraph" in paragraph (4) of that Article is deemed to be replaced with "Article 67-17, paragraph (9)", the phrase "the interest received" with "the margin", and the phrase "that interest" with "that margin".

⑪The amount of loss arising from the redemption of book-entry government bonds, book-entry municipal bonds, specified book-entry corporate bonds, etc. (excluding those held by a specially related person, prescribed in Article 5-3, paragraph (2), of the person issuing those specified book-entry corporate bonds, etc.), private foreign bonds (excluding those held by a specially related person, prescribed in Article 6, paragraph (4), of the person issuing those private foreign bonds) or specified book-entry discount bonds (excluding those held by a specially related person, prescribed in Article 41-13-3, paragraph (4), of the issuer of those specified book-entry discount bonds) held by a foreign corporation (or, for specified book-entry discount bonds, the amount of loss arising from the holding of those specified book-entry discount bonds and any other amount specified by Cabinet Order) is deemed not to exist for the purpose of applying the provisions of laws and regulations concerning corporation tax.

⑫The provisions of paragraphs (1) through (3), paragraph (6), paragraph (7), paragraph (9) and the preceding paragraph do not apply to that which, out of the profit from redemption prescribed in paragraph (1), the profit from redemption prescribed in paragraph (2), the profit from redemption prescribed in paragraph (3), the income arising from holding prescribed in paragraph (6), the lending fees, etc. prescribed in paragraph (7), the margin prescribed in paragraph (9) or the amount of loss prescribed in the preceding paragraph, is received by a foreign corporation that has a permanent establishment, or arises for a foreign corporation that has a permanent establishment, and falls under the domestic source income listed in Article 141, item (i), (a) of the Corporation Tax Act.

⑬The determination of whether a person receiving payment of profit from redemption, prescribed in paragraph (2), of specified book-entry corporate bonds, etc. is a specially related person prescribed in that paragraph, and other necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.

①In each business year of a domestic corporation commencing on or after April 1, 2016, if, because the amount that the domestic corporation has treated as the amount of consideration for an internal dealing prescribed in Article 69, paragraph (4), item (i) of the Corporation Tax Act (hereinafter referred to as an "internal dealing" in this Article) between its head office, etc. prescribed in that item and a foreign office or similar establishment prescribed in that item (referred to as a "foreign office or similar establishment" in paragraph (4) and paragraph (13)) differs from the arm's length price, the amount of revenue pertaining to that internal dealing becomes excessive, or the amount of losses, etc. (meaning amounts equivalent to the amounts listed in the items of Article 22, paragraph (3) of that Act pertaining to that internal dealing) becomes too small, in the calculation of the domestic corporation's amount of foreign-source income prescribed in Article 69, paragraph (1) of that Act for that business year, that internal dealing is to be treated as having been conducted at the arm's length price for the purpose of calculating the domestic corporation's amount of foreign-source income prescribed in Article 69, paragraph (1) of that Act for that business year.

②The arm's length price prescribed in the preceding paragraph means the amount calculated, for the amount that should be treated as the amount of consideration for an internal dealing, by a method equivalent to the methods prescribed in Article 66-4-3, paragraph (2).

③A domestic corporation that has internal dealings in a business year must prepare or obtain, by the due date for filing the return under the provisions of Article 74, paragraph (1) of the Corporation Tax Act for that business year, 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 (1) pertaining to those internal dealings (including, if an electronic or magnetic record (meaning a record made in an electronic form, a magnetic form or any other form that cannot be perceived by the human senses, which is used in information processing by computer; hereinafter the same applies in this Article) has been prepared in lieu of preparing those documents, that electronic or magnetic record), and must preserve them as provided by Order of the Ministry of Finance.

④If the internal dealings of a domestic corporation with a single foreign office or similar establishment in the business year preceding a given business year (or, if the domestic corporation came to have that single foreign office or similar establishment in that given business year, the internal dealings with that single foreign office or similar establishment in that given business year) fall under all of the following items, or in the case specified by Cabinet Order as the case where there were no internal dealings with that single foreign office or similar establishment in the preceding business year, the 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 (1) pertaining to the domestic corporation's internal dealings with that single foreign office or similar establishment in that given business year:

⑤If a relevant official of the National Tax Agency, or a relevant official of the tax office or the Regional Taxation Bureau having jurisdiction over a domestic corporation's place for tax payment, has requested the domestic corporation to present or submit the documents specified by Order of the Ministry of Finance prescribed in paragraph (3) pertaining to an internal transaction subject to contemporaneous documentation (meaning an internal dealing other than an internal dealing to which the provisions of the preceding paragraph apply; hereinafter the same applies in this paragraph) in each business year (including, if electronic or magnetic records have been prepared or preserved in lieu of preparing or preserving those documents, those electronic or magnetic records; hereinafter the same applies in this paragraph) or copies thereof, and they have not been presented or submitted by the date designated by the official, within a period not exceeding 45 days from the date of the request, in consideration of the number of days normally required to prepare for the presentation or submission of the requested documents or copies thereof, or has requested the domestic 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 (1) (including an amount deemed to be that arm's length price pursuant to the main clause of Article 66-4, paragraph (8) as applied mutatis mutandis pursuant to paragraph (13)) pertaining to an internal transaction subject to contemporaneous documentation in each business year (including, if electronic or magnetic records have been prepared or preserved in lieu of preparing or preserving those documents, those electronic or magnetic records; hereinafter the same applies in this paragraph) or copies thereof, and they have not been presented or submitted by the date designated by the official, within a period not exceeding 60 days from the date of the request, in consideration of the number of days normally required to prepare for the presentation or submission of the requested documents or copies thereof, the official may, when it is necessary for calculating the arm's length price prescribed in paragraph (1) pertaining to the domestic corporation's internal transaction subject to contemporaneous documentation in each business year, and to the extent found to be necessary, ask questions of a person engaged in a business of the same type as the domestic corporation's business pertaining to that internal transaction subject to contemporaneous documentation, inspect the books and documents relating to that business (including, if electronic or magnetic records have been prepared or preserved in lieu of preparing or preserving them, those electronic or magnetic records; hereinafter the same applies in this Article), or request the presentation or submission of those books and documents (including copies thereof).

⑥If a relevant official of the National Tax Agency, or a relevant official of the tax office or the Regional Taxation Bureau having jurisdiction over a domestic corporation's place for tax payment, has requested the domestic 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 (1) (including an amount deemed to be that arm's length price pursuant to the main clause of Article 66-4, paragraph (8) as applied mutatis mutandis pursuant to paragraph (13)) pertaining to an internal transaction exempt from contemporaneous documentation (meaning an internal dealing to which the provisions of paragraph (4) apply; hereinafter the same applies in this paragraph) in each business year (including, if electronic or magnetic records have been prepared or preserved in lieu of preparing or preserving those documents, those electronic or magnetic records; hereinafter the same applies in this paragraph) or copies thereof, and they have not been presented or submitted by the date designated by the official, within a period not exceeding 60 days from the date of the request, in consideration of the number of days normally required to prepare for the presentation or submission of the requested documents or copies thereof, the official may, when it is necessary for calculating the arm's length price prescribed in paragraph (1) pertaining to the domestic corporation's internal transaction exempt from contemporaneous documentation in each business year, and to the extent found to be necessary, ask questions of a person engaged in a business of the same type as the domestic corporation's business pertaining to that internal transaction exempt from contemporaneous documentation, inspect the books and documents relating to that business, or request the presentation or submission of those books and documents (including copies thereof).

⑦A relevant official of the National Tax Agency, or a relevant official of the tax office or the Regional Taxation Bureau having jurisdiction over a domestic corporation's place for tax payment, may, when it is necessary for calculating the arm's length price prescribed in paragraph (1) pertaining to the domestic corporation's internal dealings, retain the books and documents (including copies thereof) submitted pursuant to the provisions of the preceding two paragraphs.

⑧The authority of the relevant officials under the provisions of the preceding three paragraphs must not be construed as being granted for the purpose of criminal investigation.

⑨When a relevant official of the National Tax Agency, a Regional Taxation Bureau or a tax office asks questions, conducts an inspection or requests presentation or submission under the provisions of paragraph (5) or (6), the official must carry a certificate showing the official's identity and must present it if so requested by a person concerned.