①The provisions then in force continue to govern the calculation of the amount of applicable income prescribed in Article 68-93-2, paragraph (3) of the Former Act on Special Measures Concerning Taxation for business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date.

②The provisions of Article 68-93-2, 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 corporation 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.

③The provisions of Article 68-93-3 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 corporation 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 68-93-3, 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 corporation prescribed in that paragraph that began before the Effective Date.

④The provisions of Article 68-93-4 of the New Act on Special Measures Concerning Taxation (excluding paragraphs (3) and (9)) apply in the case where a consolidated corporation that is a specially-related shareholder, etc. prescribed in paragraph (1) of that Article has an amount of dividends of surplus and similar distributions prescribed in that paragraph 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 that is a specially-related shareholder, etc. prescribed in Article 68-93-4, paragraph (2) of the Former Act on Special Measures Concerning Taxation had, in a consolidated business year that began before the Effective Date, an amount of dividends of surplus and similar distributions prescribed in paragraph (1) of that Article received from a specified foreign corporation prescribed in paragraph (2) of that Article.

⑤The provisions of Article 68-93-4, paragraphs (3) and (9) 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.

⑥With regard to the application of the provisions of Article 68-93-4, paragraph (6) 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 "Article 68-92, paragraph (6), item (ii)" in the row for Article 68-92, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 68-92, paragraph (6), items (ii) and (iii)".

⑦Out of the individually taxable retained amount prescribed in Article 68-93-8, paragraph (1) of the Former Act for 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 corresponding to the number of shares, etc. held indirectly prescribed in Article 68-93-4, paragraph (10), 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 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 68-93-8, paragraph (1) of the Former Act (including an amount deemed to be the individually taxed retained amount prescribed in Article 68-93-8, paragraph (1) of the Former Act pursuant to the provisions of Article 68-92, paragraph (3) of the Former Act as applied with the replacement of terms pursuant to paragraph (2) or (3) of Article 68-93-8 of the Former Act, 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 corporation 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 68-93-4, paragraphs (7) through (10) 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 68-93-4, 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 60, paragraph (4) of the Supplementary Provisions of the 2009 Amendment Act.

⑧With regard to the application of the provisions of Article 68-93-4, paragraph (12) 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 Article 68-92, 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".

⑨With regard to the application of the provisions of Article 68-93-4, paragraph (12) 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 Article 68-92, 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 Article 68-92, 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".

⑩With regard to the application of the provisions of Article 68-93-4, paragraph (12) 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 "Article 68-92, paragraph (6), item (ii)" in the row for Article 68-92, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 68-92, paragraph (6), item (iii)".

The provisions then in force continue to govern donations prescribed in Article 68-96-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation to a specified regional employment company prescribed in that paragraph which a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation makes within the period of validity of the designation prescribed in that paragraph that was made before the Effective Date.

The provisions of Article 68-102 of the New Act on Special Measures Concerning Taxation apply to corporation tax for consolidated business years of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation in the case where a company split or distribution in kind is carried out on or after October 1, 2010 or where a dissolution or an order commencing bankruptcy proceedings takes place on or after that date, and the provisions then in force continue to govern corporation tax for consolidated business years of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation in the case where a company split or post-formation acquisition of assets was carried out before that date or where a dissolution took place before that date.

The provisions of Article 68-109-2 of the New Act on Special Measures Concerning Taxation apply to corporation tax for consolidated business years of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation in the case where a merger, company split or share exchange is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax for consolidated business years of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation in the case where a merger, company split or share exchange was carried out before that date.