①With regard to the calculation of the applicable amount prescribed in Article 40-7, paragraph (3) of the Former Act on Special Measures Concerning Taxation pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 40-7, 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 pertaining to business years of a specified foreign corporation prescribed in that paragraph beginning on or after the Effective Date and to the partially taxable amount prescribed in that paragraph pertaining to that partially applicable amount.

③The provisions of Article 40-8 of the New Act on Special Measures Concerning Taxation apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a resident who is a specially related shareholder, etc. prescribed in that paragraph receives from a foreign corporation on or after the Effective Date, and the provisions then in force continue to govern cases where there is an amount of dividend of surplus, etc. prescribed in Article 40-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a resident who is a specially related shareholder, etc. prescribed in that paragraph received from a specified foreign corporation prescribed in that paragraph before the Effective Date.

④The amount of the portion of the taxable retained amount prescribed in Article 40-11, paragraph (1) of the Former Act pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before April 1, 2009 (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly prescribed in Article 40-8, paragraph (2), 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 corporation held by a resident) that corresponds to the year that includes the dividend date prescribed in (a) of that item of that resident, or the amount of the portion of the amount of undeducted dividends, etc. prescribed in Article 40-11, paragraph (2) of the Former Act (limited to the amount specified by Cabinet Order as the amount of the portion corresponding to the number of shares, etc. held indirectly in that specified foreign corporation held by that resident) that corresponds to each year within the preceding two years prescribed in (b) of that item of that resident, is deemed to be the amount listed in (a) or (b) of that item of that resident, and the provisions of Article 40-8, paragraph (2) 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 the items of Article 40-8, paragraph (1) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 32, paragraph (3) of the Supplementary Provisions of the 2009 Amendment Act.