①The provisions of Article 68-90, paragraphs (1) and (3) of the New Act on Special Measures Concerning Taxation apply to the amount of applicable income prescribed in paragraph (1) of that Article for business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date and to the individually taxable amount prescribed in that paragraph pertaining to that amount of applicable income, and the provisions then in force continue to govern the amount of applicable income prescribed in Article 68-90, paragraph (1) of the Former Act on Special Measures Concerning Taxation for business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date and the individually taxable amount prescribed in that paragraph pertaining to that amount of applicable income.

②The provisions then in force continue to govern the calculation of the amount of applicable income prescribed in Article 68-90, paragraph (3) of the Former Act on Special Measures Concerning Taxation for business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

③The provisions of Article 68-90, paragraphs (4) and (5) of the New Act on Special Measures Concerning Taxation apply to the partially applicable amount prescribed in paragraph (4) of that Article for business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date and to the individually taxable partial amount prescribed in that paragraph pertaining to that partially applicable amount.

④The provisions of Article 68-90, paragraph (7) of the New Act on Special Measures Concerning Taxation apply in the case where the provisions of paragraph (3) or (5) of that Article are applied to the amount of applicable income prescribed in paragraph (1) of that Article or the partially applicable amount prescribed in paragraph (4) of that Article for business years of a specified foreign subsidiary, etc. prescribed in paragraph (1) of that Article beginning on or after the Effective Date, and the provisions then in force continue to govern the case where the provisions of paragraph (3) or (4) of Article 68-90 of the Former Act on Special Measures Concerning Taxation are applied to the amount of applicable income prescribed in paragraph (1) of that Article for business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

⑤The provisions of Article 68-91 of the New Act on Special Measures Concerning Taxation apply to the amount of foreign country's corporate tax prescribed in paragraph (1) of that Article pertaining to the individually taxable amount or the individually taxable partial amount prescribed in that paragraph for business years of a specified foreign subsidiary, etc. prescribed in that paragraph beginning on or after the Effective Date, and the provisions then in force continue to govern the amount of foreign country's corporate tax prescribed in Article 68-91, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to the individually taxable amount prescribed in that paragraph for business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before the Effective Date.

⑥The provisions of Article 68-92 of the New Act on Special Measures Concerning Taxation (excluding paragraphs (3), (6), (7) and (10)) apply in the case where a consolidated corporation has an amount of dividends of surplus and similar distributions prescribed in paragraph (1) of that Article received from a foreign corporation in a consolidated business year beginning on or after the Effective Date, and the provisions then in force continue to govern the case where a consolidated corporation had, in a consolidated business year that began before the Effective Date, an amount of dividends of surplus and similar distributions prescribed in Article 68-92, paragraph (1) of the Former Act on Special Measures Concerning Taxation received from a specified foreign subsidiary, etc. prescribed in paragraph (2) of that Article.

⑦The provisions of Article 68-92, paragraphs (3) and (10) of the New Act on Special Measures Concerning Taxation apply to the amount of dividends of surplus and similar distributions prescribed in paragraph (3) of that Article pertaining to shares or capital contributions which a consolidated corporation acquires (including succession through a qualified merger or qualified company split by split-off) on or after October 1, 2010.

⑧The provisions of Article 68-92, paragraphs (6) and (7) of the New Act on Special Measures Concerning Taxation apply to the individually taxed amount for each consolidated business year within the preceding ten years of a consolidated corporation prescribed in paragraph (6) of that Article and to the individually taxed amount for business years within ten years before the company split, etc. of a split corporation, etc. prescribed in paragraph (7) of that Article, in the case where a qualified company split by split-off or a qualified in-kind distribution (if the qualified in-kind distribution is a distribution of residual assets, limited to one resulting from a dissolution on or after October 1, 2010) is carried out on or after October 1, 2010, and the provisions then in force continue to govern the individually taxed amount for each consolidated business year within the preceding ten years of a consolidated corporation prescribed in Article 68-92, paragraph (6) of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 18 (limited to the amending provisions listed in Article 1, item (iii), (i) of the Supplementary Provisions) and the individually taxed amount for business years within ten years before the company split or business years within ten years before the company split, etc. of a split corporation, etc. prescribed in paragraph (7) of that Article, in the case where a qualified company split by split-off or a qualified post-formation acquisition of assets was carried out before that date. In this case, with regard to the application of the provisions of paragraph (6), item (ii) of that Article in the case where a qualified company split by split-off is carried out during the period from the Effective Date to September 30, 2010, the phrase "specified foreign subsidiary, etc." in that item is deemed to be replaced with "foreign corporation".

⑨Out of the individually taxable retained amount prescribed in Article 68-92, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 5 of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009; referred to as the "2009 Amendment Act" in this paragraph and paragraph (7) of the following Article) (referred to as the "Former Act" in this paragraph and paragraph (7) of the following Article) for business years of a specified foreign subsidiary, etc. prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount corresponding to the number of shares, etc. held indirectly prescribed in Article 68-92, paragraph (11), item (ii), (a) of the New Act on Special Measures Concerning Taxation (referred to as the "number of shares, etc. held indirectly" in this paragraph) in that specified foreign subsidiary, etc. held by a consolidated corporation; the same applies hereinafter in this paragraph), the amount corresponding to the dividend consolidated business year prescribed in (a) of that item (referred to as the "dividend consolidated business year" in this paragraph) of that consolidated corporation, or, out of the individually taxed retained amount prescribed in Article 68-92, paragraph (1) of the Former Act (including an amount deemed to be the individually taxed retained amount prescribed in paragraph (1) of that Article pursuant to the provisions of paragraph (2) or (3) of that Article, and limited to the amount specified by Cabinet Order as the amount corresponding to the number of shares, etc. held indirectly in that specified foreign subsidiary, etc. held by that consolidated corporation; the same applies hereinafter in this paragraph), the amount corresponding to each consolidated business year within the preceding two years prescribed in (b) of that item (referred to as "each consolidated business year within the preceding two years" in this paragraph) of that consolidated corporation (excluding the amount equivalent to the amount of dividends of surplus and similar distributions prescribed in (b) of that item that is deducted pursuant to the provisions of (b) of that item), is deemed to be the amount listed in (a) or (b) of that item for the dividend consolidated business year or each consolidated business year within the preceding two years corresponding to the consolidated business year or the period of the business year to which the individually taxable retained amount or the individually taxed retained amount of that consolidated corporation pertains, and the provisions of Article 68-92, paragraphs (8) through (11) of the New Act on Special Measures Concerning Taxation apply. In this case, the amount deemed to be the amount listed in (a) or (b) of that item is not to be included in the amount deemed to be the amount listed in each item of Article 68-92, paragraph (3) of the Act on Special Measures Concerning Taxation as amended by the provisions of Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 59, paragraph (4) of the Supplementary Provisions of the 2009 Amendment Act.

⑩With regard to the application of the provisions of Article 68-92, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a merger is carried out during the period from the Effective Date to September 30, 2010, in the row for paragraph (6), item (i) of the table in that paragraph, the phrase "business year within ten years before the merger, etc." is deemed to be replaced with "business year within ten years before the merger", and the phrase "business year within two years before the merger, etc." with "business year within two years before the merger".

⑪With regard to the application of the provisions of Article 68-92, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a company split by split-off is carried out during the period from the Effective Date to September 30, 2010, in the row for paragraph (6), item (ii) of the table in that paragraph, the phrase "business year within ten years before the company split, etc." is deemed to be replaced with "business year within ten years before the company split", the phrase "business year within two years before the company split, etc." with "business year within two years before the company split", the phrase "number of shares, etc. held directly" with "number of shares, etc. of the specified foreign subsidiary, etc. held directly", and the phrase "number of shares, etc. held indirectly" with "number of shares, etc. of the foreign corporation held indirectly", and in the row for paragraph (7) of that table, the phrase "business year within ten years before the company split, etc." with "business year within ten years before the company split or business year within ten years before the company split, etc.", and the phrase "business year within two years before the company split, etc." with "business year within two years before the company split".

⑫With regard to the application of the provisions of Article 68-92, paragraph (13) of the New Act on Special Measures Concerning Taxation in the case where a company split by spin-off, capital contribution in kind or post-formation acquisition of assets is carried out during the period from the Effective Date to September 30, 2010, the phrase "paragraph (6), item (ii)" in the row for paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "paragraph (6), item (iii)".