①With regard to the calculation of the applicable amount prescribed in Article 66-9-2, 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 66-9-2, 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 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 66-9-3 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 taxable amount or the partially taxable amount prescribed in that paragraph pertaining to 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 66-9-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation pertaining to the taxable amount prescribed in that paragraph pertaining to business years of a specified foreign corporation prescribed in that paragraph that began before the Effective Date.

④The provisions of Article 66-9-4 of the New Act on Special Measures Concerning Taxation (excluding paragraphs (3) and (9)) apply where there is an amount of dividend of surplus, etc. prescribed in paragraph (1) of that Article that a domestic corporation that is a specially related shareholder, etc. prescribed in that paragraph receives from a foreign corporation in a business year beginning 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 paragraph (1) of Article 66-9-4 of the Former Act on Special Measures Concerning Taxation that a domestic corporation that is a specially related shareholder, etc. prescribed in paragraph (2) of that Article received from a specified foreign corporation prescribed in that paragraph in a business year that began before the Effective Date.

⑤The provisions of Article 66-9-4, paragraphs (3) and (9) of the New Act on Special Measures Concerning Taxation apply to the amount of dividend of surplus, etc. prescribed in paragraph (3) of that Article pertaining to shares or capital contributions that a domestic 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 66-9-4, 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 66-8, paragraph (6), item (ii)" in the row for Article 66-8, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 66-8, paragraph (6), items (ii) and (iii)".

⑦The amount of the portion of the taxable retained amount prescribed in Article 66-9-8, 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 66-9-4, 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 domestic corporation; the same applies hereinafter in this paragraph) that corresponds to the dividend business year prescribed in (a) of that item (referred to as the "dividend business year" in this paragraph) of that domestic corporation, or the amount of the portion of the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act (including an amount deemed, pursuant to the provisions of Article 66-8, paragraph (3) of the Former Act as applied with the replacement of terms pursuant to paragraph (2) or (3) of Article 66-9-8 of the Former Act, to be the taxed retained amount prescribed in Article 66-9-8, paragraph (1) of the Former Act, and 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 domestic corporation; the same applies hereinafter in this paragraph) that corresponds to each business year within the preceding two years prescribed in (b) of that item (referred to as "each business year within the preceding two years" in this paragraph) of that domestic corporation (excluding the amount equivalent to the amount of dividend of surplus, etc. 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 business year or each business year within the preceding two years corresponding to the period of the business year or consolidated business year pertaining to the taxable retained amount or taxed retained amount of that domestic corporation, and the provisions of Article 66-9-4, 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 the items of Article 66-9-4, paragraph (3) of the Act on Special Measures Concerning Taxation as amended by Article 5 of the 2009 Amendment Act pursuant to the provisions of Article 45, paragraph (4) of the Supplementary Provisions of the 2009 Amendment Act.

⑧With regard to the application of the provisions of Article 66-9-4, 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, the phrase "business year within ten years before the merger, etc." in the row for Article 66-8, paragraph (6), item (i) of the table in that paragraph 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." is deemed to be replaced with "business year within two years before the merger".

⑨With regard to the application of the provisions of Article 66-9-4, 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 66-8, 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. held directly pertaining to the specified foreign subsidiary, etc.", and the phrase "number of shares, etc. held indirectly" with "number of shares, etc. held indirectly pertaining to the foreign corporation", and in the row for Article 66-8, paragraph (7) of that table, 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 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 66-9-4, 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 66-8, paragraph (6), item (ii)" in the row for Article 66-8, paragraph (6), item (ii) of the table in that paragraph is deemed to be replaced with "Article 66-8, paragraph (6), item (iii)".

With regard to donations prescribed in Article 66-12, paragraph (1) of the Former Act on Special Measures Concerning Taxation to a specified regional employment company prescribed in that paragraph that a corporation makes within the period of validity of a designation prescribed in that paragraph that was made before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 66-13, paragraph (1) of the New Act on Special Measures Concerning Taxation (excluding the part concerning item (i)) apply to corporation tax of a corporation for business years in the case where a dissolution takes place on or after October 1, 2010, and the provisions then in force continue to govern corporation tax pertaining to business years during liquidation of a corporation in the case where a dissolution took place before that date.

The provisions of Article 67-4 of the New Act on Special Measures Concerning Taxation apply to corporation tax of a corporation for business years in the case where a company split or distribution in kind is carried out on or after October 1, 2010, and the provisions then in force continue to govern corporation tax of a corporation for business years in the case where a company split or post-formation acquisition of assets was carried out before that date.

The provisions of Article 67-6, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to distributions of proceeds of a specified stock investment trust prescribed in that paragraph received by a corporation that is dissolved on or after October 1, 2010, and the provisions then in force continue to govern distributions of proceeds of a specified stock investment trust prescribed in Article 67-6, paragraph (1) of the Former Act on Special Measures Concerning Taxation received by a corporation that was dissolved before that date.

①The provisions of Article 67-14, paragraph (1), item (i), (b), 2. and (c) (limited to the part concerning base specified equity prescribed in (c) of that item) of the New Act on Special Measures Concerning Taxation apply to corporation tax of a specific purpose company prescribed in that paragraph (referred to as a "specific purpose company" in this paragraph) for business years beginning on or after the Effective Date (for a specific purpose company established before the Effective Date that did not file the notification of commencement of business prescribed in Article 4, paragraph (2) of the Act on the Securitization of Assets (Act No. 105 of 1998) by March 31, 2015 (referred to as a "company yet to file its notification" in this paragraph), limited to business years ending on or after April 1, 2015, and for a specific purpose company established before the Effective Date (excluding a company yet to file its notification), limited to business years ending on or after the day on which it first files a notification of change, etc. (meaning a notification of a change in the matters listed in Article 5, paragraph (1), item (i) of the Act on the Securitization of Assets under the provisions of Article 9, paragraph (1) of that Act, or a notification under the provisions of Article 10, paragraph (1) of that Act, pertaining to the asset securitization plan prescribed in Article 67-14, paragraph (1), item (i), (c) of the New Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) on or after the Effective Date), and the provisions then in force continue to govern corporation tax of a specific purpose company for business years that began before the Effective Date (including, for a company yet to file its notification, business years that began on or after the Effective Date and ended before April 1, 2015, and, for a specific purpose company established before the Effective Date (excluding a company yet to file its notification), business years that began on or after the Effective Date and ended before the day on which it first files a notification of change, etc. on or after the Effective Date). In this case, with regard to the application of the provisions of Article 67-14, paragraph (1), item (i), (b), 2. of the New Act on Special Measures Concerning Taxation to business years of a company yet to file its notification ending before the day on which it first files a notification of change, etc., the phrase "expected to be held" in (b), 2. of that item is deemed to be replaced with "subscribed for".

②The provisions of Article 67-14, paragraph (1), item (i), (c) of the New Act on Special Measures Concerning Taxation (excluding the part concerning base specified equity prescribed in (c) of that item) apply to corporation tax of a specific purpose company prescribed in that paragraph for business years ending on or after the Effective Date, and the provisions then in force continue to govern corporation tax of a specific purpose company prescribed in Article 67-14, paragraph (1) of the Former Act on Special Measures Concerning Taxation for business years that ended before the Effective Date.

③The provisions of Article 67-14, paragraph (6) of the New Act on Special Measures Concerning Taxation apply to the amount of dividends of profits prescribed in that paragraph received by a corporation that is dissolved on or after October 1, 2010, and the provisions then in force continue to govern the amount of dividends of profits prescribed in Article 67-14, paragraph (6) of the Former Act on Special Measures Concerning Taxation received by a corporation that was dissolved before that date.

The provisions of Article 67-15, paragraph (7) of the New Act on Special Measures Concerning Taxation apply to the amount of dividends and similar income prescribed in that paragraph received by a corporation that is dissolved on or after October 1, 2010, and the provisions then in force continue to govern the amount of dividends and similar income prescribed in Article 67-15, paragraph (7) of the Former Act on Special Measures Concerning Taxation received by a corporation that was dissolved before that date.