①The provisions of Article 40-4, paragraphs (1), (2) and (6) of the New Act on Special Measures Concerning Taxation apply to the amount of applicable retained income prescribed in paragraph (1) of that Article for a business year, ending on or after the Effective Date, of a specified foreign subsidiary, etc. prescribed in that paragraph and the taxable retained amount prescribed in that paragraph pertaining to that amount of applicable retained income, and with regard to the amount of applicable retained income prescribed in Article 40-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation for a business year, ending before the Effective Date, of a specified foreign subsidiary, etc. prescribed in that paragraph and the taxable retained amount prescribed in that paragraph pertaining to that amount of applicable retained income, the provisions then in force continue to govern.

②The provisions of Article 40-4, paragraphs (7) and (8) of the New Act on Special Measures Concerning Taxation apply to the amount of applicable retained income prescribed in paragraph (1) of that Article, as applied pursuant to the provisions of paragraph (7) of that Article, for a business year, ending on or after the effective date of the Trust Act, of the trustee of a foreign trust prescribed in paragraph (7) of that Article pertaining to that foreign trust, and the taxable retained amount prescribed in paragraph (1) of that Article pertaining to that amount of applicable retained income.