②Where a corporation prescribed in Article 57-8, paragraph (1) of the Former Act on Special Measures Concerning Taxation has, as of the date of commencement of the business year first beginning on or after April 1, 2012 (or, if the business year first beginning on or after April 1 of that year falls under a consolidated business year prescribed in Article 2, paragraph (2), item (xix) of the Act on Special Measures Concerning Taxation before the amendment by Article 16 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020) (referred to as the "Act on Special Measures Concerning Taxation Before the 2020 Amendment" in paragraph (9)) (hereinafter referred to as a "consolidated business year" in this Article), the date of commencement of that consolidated business year), the amount of a reserve for special repairs prescribed in Article 57-8, paragraph (3) of the Former Act on Special Measures Concerning Taxation (limited to that pertaining to special repairs (meaning the repairs specified in Article 57-8, paragraph (1), item (ii) of the Former Act on Special Measures Concerning Taxation to be carried out on the fixed assets listed in that item, the repairs carried out in order to undergo the inspections specified by Order of the Ministry of Finance that are periodically carried out on spherical gas holders prescribed in Article 2, paragraph (13) of the Gas Business Act (Act No. 51 of 1954) as amended by Article 5 of the Act Partially Amending the Electricity Business Act, etc., and Other Matters (Act No. 47 of 2015) (referred to as the "New Gas Business Act" in Article 82, paragraph (2) of the Supplementary Provisions) that are used for the gas retail business prescribed in paragraph (2) of that Article or the general gas pipeline service business prescribed in paragraph (5) of that Article and are specified by Order of the Ministry of Finance, or the repairs specified in Article 57-8, paragraph (1), item (iv) of the Former Act on Special Measures Concerning Taxation to be carried out on the fixed assets listed in that item; the same applies in paragraph (4), items (i) and (ii))), then, in each business year (excluding a business year that falls under a consolidated business year) that includes any day within four years (or, if that corporation is a small and medium sized enterprise prescribed in Article 42-4, paragraph (8), item (vi) of the Act on Special Measures Concerning Taxation before the amendment by Article 11 of the Act Partially Amending the Income Tax Act, etc. (Act No. 6 of 2019) (referred to as the "2019 Former Act on Special Measures Concerning Taxation" in Article 82, paragraph (2) of the Supplementary Provisions) (hereinafter referred to as a "small and medium sized enterprise" in this Article), ten years) from that date of commencement, an amount equivalent to the amount calculated by multiplying the amount of that reserve for special repairs by the number of months in each business year and dividing the result by 48 (or, if that corporation is a small and medium sized enterprise, 120) (referred to as the "equal reversal amount over four years, etc." in the following paragraph) is included in gross profit in calculating the amount of income for each of those business years.

③In the case referred to in the preceding paragraph, if the equal reversal amount over four years, etc. exceeds the amount of the reserve for special repairs as of the end of that business year (or, if by that date there is any amount that has been included, or is to be included, in gross profit pursuant to the provisions of the following paragraph out of the amount of the reserve for special repairs prescribed in the preceding paragraph (including any amount included in gross profit pursuant to the provisions of Article 82, paragraph (4) of the Supplementary Provisions), or any amount that was included in gross profit pursuant to the provisions of the preceding paragraph by the end of the preceding business year (or, if the business year that includes the day before the date of commencement of that business year falls under a consolidated business year, the consolidated business year that includes that day before) (including any amount included in gross profit pursuant to the provisions of paragraph (2) of that Article), the amount remaining after deducting those amounts; the same applies hereinafter in this Article), that equal reversal amount over four years, etc. is the amount of that reserve for special repairs.

④Where a corporation receiving the application of the provisions of paragraph (2) comes to fall under any of the cases listed in the following items (excluding the case where it has transferred an asset with a reserve set (meaning the fixed assets pertaining to the reserve for special repairs referred to in that paragraph; the same applies hereinafter in this Article) through a qualified merger, qualified company split or qualified capital contribution in kind), an amount equivalent to the amount specified in that item is included in gross profit in calculating the amount of income for the business year that includes the date on which it came to fall under that case (or, in the case listed in item (iii), the business year that includes the day before the date of the merger):

⑤Where a corporation receiving the application of the provisions of paragraph (2) has had the approval for filing a blue return revoked, or has filed a written notification to the effect that it will cease to file returns using a blue return, by the day on which three years (or, if that corporation is a small and medium sized enterprise, nine years) have elapsed from the date of commencement of the business year first beginning on or after April 1, 2012 (or, if the business year first beginning on or after April 1 of that year falls under a consolidated business year, the date of commencement of that consolidated business year), the amount of the reserve for special repairs as of the date on which the fact that caused the revocation of that approval occurred or the date on which that written notification was filed (or, if the date on which that written notification was filed is after the end of the business year in which the corporation ceased to file returns using a blue return, the end of that business year) is included in gross profit, pursuant to the provisions of Cabinet Order, in calculating the amount of income for each business year from the business year that includes that date to the business year that includes the day before the day on which two years have elapsed from the date of commencement of that business year (or, if the business year that includes the day before the day on which two years have elapsed from the date of commencement of that business year (hereinafter referred to as the "date two years have passed" in this paragraph) falls under a consolidated business year, the business year that includes the day before the date of commencement of the consolidated business year that first began during the period from the day following the date of commencement of that business year to the date two years have passed). In such a case, the provisions of paragraph (2), the preceding paragraph, paragraph (8), paragraph (11) and paragraph (15) do not apply to that amount of the reserve for special repairs.

⑥Where, with regard to a corporation receiving the application of the provisions of paragraph (2), the approval under the provisions of Article 64-9, paragraph (1) of the Corporation Tax Act has ceased to be effective pursuant to the provisions of Article 64-10, paragraphs (4) through (6) of that Act, and that corporation, as a result of having had the approval for filing a blue return revoked or having filed a written notification to the effect that it will cease to file returns using a blue return, has ceased to be a person who is able to file the tax return, etc. for the business year that includes the day before the date on which that approval ceased to be effective (or, if that day before is the end of a business year of the group tax sharing parent corporation pertaining to that corporation, the date on which that approval ceased to be effective) using a blue return, the amount of the reserve for special repairs as of the end of that business year is included in gross profit in calculating the amount of income for that business year. In such a case, the provisions of paragraph (2), the preceding two paragraphs, paragraph (8), paragraph (11) and paragraph (15) do not apply.

⑦The number of months referred to in paragraph (2) is calculated according to the calendar, and any fraction of less than one month is counted as one month.

⑧Where a corporation receiving the application of the provisions of paragraph (2) has transferred an asset with a reserve set to the merging corporation through a qualified merger (excluding the case prescribed in the first sentence of Article 82, paragraph (6) of the Supplementary Provisions), the amount of the reserve for special repairs immediately before that qualified merger is to be taken over by that merging corporation. In such a case, the amount of the reserve for special repairs that the merging corporation has taken over is deemed to be the amount of the reserve for special repairs referred to in paragraph (2) that the merging corporation has as of the date of that qualified merger (or, if the business year of that merging corporation that includes the date of that qualified merger falls under a consolidated business year, the amount of the reserve for special repairs referred to in paragraph (2) of that Article).

⑨In the case referred to in the preceding paragraph or Article 82, paragraph (6) of the Supplementary Provisions, if the merging corporation referred to in those provisions (excluding one that falls under a consolidated corporation prescribed in Article 2, paragraph (2), item (x)-6 of the Act on Special Measures Concerning Taxation Before the 2020 Amendment (hereinafter referred to as a "consolidated corporation" in this Article) after that qualified merger) is not a person who is able to file the tax return, etc. for the business year that includes the date of that qualified merger using a blue return, the amount of the reserve for special repairs as of the end of that business year is included in gross profit in calculating the amount of income for that business year.

⑩With regard to the application of the provisions of paragraph (2) to each business year from the business year that includes the date of the qualified merger onward (or, if the business year that includes the date of that qualified merger falls under a consolidated business year, each business year after that consolidated business year) of the merging corporation referred to in paragraph (8) or Article 82, paragraph (6) of the Supplementary Provisions (excluding one that falls under a consolidated corporation after that qualified merger), the amount of the reserve for special repairs prescribed in paragraph (2) is to include the amount of the reserve for special repairs that that merging corporation is deemed to have pursuant to the provisions of paragraph (8) or paragraph (6) of that Article. In such a case, with regard to the amount of the reserve for special repairs that that merging corporation is deemed to have, the phrase "by the number of months in each business year and dividing the result by 48 (or, if that corporation is a small and medium sized enterprise, 120)" in paragraph (2) is deemed to be replaced with "by the number of months in each business year (or, for the business year that includes the date of that qualified merger, the number of months in the period from that date to the end of the business year that includes that date) and dividing the result by the number of months obtained by deducting the number of months in the elapsed period (meaning the period from the date of commencement of the business year first beginning on or after April 1, 2012 (or, if the business year first beginning on or after April 1 of that year falls under a consolidated business year, the date of commencement of that consolidated business year) to the day before the date of that qualified merger) from 48 months (or, if that corporation is a small and medium sized enterprise, 120 months)".

⑪Where a corporation receiving the application of the provisions of paragraph (2) has transferred an asset with a reserve set to the successor corporation in a company split through a qualified company split (excluding the case prescribed in the first sentence of Article 82, paragraph (8) of the Supplementary Provisions), the amount of the reserve for special repairs pertaining to that asset with a reserve set immediately before that qualified company split is to be taken over by that successor corporation in a company split. In such a case, the amount of the reserve for special repairs that the successor corporation in a company split has taken over is deemed to be the amount of the reserve for special repairs referred to in paragraph (2) that the successor corporation in a company split has as of the date of that qualified company split (or, if the business year of that successor corporation in a company split that includes the date of that qualified company split falls under a consolidated business year, the amount of the reserve for special repairs referred to in paragraph (2) of that Article).

⑫In the case referred to in the preceding paragraph, with regard to the business year of a corporation receiving the application of the provisions of paragraph (2) that includes the date of that qualified company split (excluding that business year if that date is the date of commencement of a business year of that corporation), the provisions of that paragraph apply by deeming the day before the date of that qualified company split to be the end of that business year. In such a case, the phrase "the number of months in each business year" in that paragraph is deemed to be replaced with "the number of months in each business year (or, for the business year that includes the date of that qualified company split, the number of months in the period from the date of commencement of the business year that includes the date of that qualified company split to the day before the date of that qualified company split)".

⑬In the case referred to in paragraph (11) or Article 82, paragraph (8) of the Supplementary Provisions, if the successor corporation in a company split referred to in those provisions (excluding one that falls under a consolidated corporation after that qualified company split) is not a person who is able to file the tax return, etc. for the business year that includes the date of that qualified company split using a blue return, the amount of the reserve for special repairs as of the end of that business year is included in gross profit in calculating the amount of income for that business year.

⑭With regard to the application of the provisions of paragraph (2) to each business year from the business year that includes the date of the qualified company split onward (or, if the business year that includes the date of that qualified company split falls under a consolidated business year, each business year after that consolidated business year) of the successor corporation in a company split referred to in paragraph (11) or Article 82, paragraph (8) of the Supplementary Provisions (excluding one that falls under a consolidated corporation after that qualified company split), the amount of the reserve for special repairs prescribed in paragraph (2) is to include the amount of the reserve for special repairs that that successor corporation in a company split is deemed to have pursuant to the provisions of paragraph (11) or paragraph (8) of that Article. In such a case, with regard to the amount of the reserve for special repairs that that successor corporation in a company split is deemed to have, the phrase "by the number of months in each business year and dividing the result by 48 (or, if that corporation is a small and medium sized enterprise, 120)" in paragraph (2) is deemed to be replaced with "by the number of months in each business year (or, for the business year that includes the date of that qualified company split, the number of months in the period from that date to the end of the business year that includes that date) and dividing the result by the number of months obtained by deducting the number of months in the elapsed period (meaning the period from the date of commencement of the business year first beginning on or after April 1, 2012 (or, if the business year first beginning on or after April 1 of that year falls under a consolidated business year, the date of commencement of that consolidated business year) to the day before the date of that qualified company split) from 48 months (or, if that corporation is a small and medium sized enterprise, 120 months)".

⑮Where a corporation receiving the application of the provisions of paragraph (2) has transferred an asset with a reserve set to the corporation receiving a capital contribution in kind through a qualified capital contribution in kind (excluding the case prescribed in the first sentence of Article 82, paragraph (11) of the Supplementary Provisions), the amount of the reserve for special repairs pertaining to that asset with a reserve set immediately before that qualified capital contribution in kind is to be taken over by that corporation receiving a capital contribution in kind. In such a case, the amount of the reserve for special repairs that the corporation receiving a capital contribution in kind has taken over is deemed to be the amount of the reserve for special repairs referred to in paragraph (2) that the corporation receiving a capital contribution in kind has as of the date of that qualified capital contribution in kind (or, if the business year of that corporation receiving a capital contribution in kind that includes the date of that qualified capital contribution in kind falls under a consolidated business year, the amount of the reserve for special repairs referred to in paragraph (2) of that Article).

⑯In the case referred to in the preceding paragraph, with regard to the business year of a corporation receiving the application of the provisions of paragraph (2) that includes the date of that qualified capital contribution in kind (excluding that business year if that date is the date of commencement of a business year of that corporation), the provisions of that paragraph apply by deeming the day before the date of that qualified capital contribution in kind to be the end of that business year. In such a case, the phrase "the number of months in each business year" in that paragraph is deemed to be replaced with "the number of months in each business year (or, for the business year that includes the date of that qualified capital contribution in kind, the number of months in the period from the date of commencement of the business year that includes the date of that qualified capital contribution in kind to the day before the date of that qualified capital contribution in kind)".

⑰In the case referred to in paragraph (15) or Article 82, paragraph (11) of the Supplementary Provisions, if the corporation receiving a capital contribution in kind referred to in those provisions (excluding one that falls under a consolidated corporation after that qualified capital contribution in kind) is not a person who is able to file the tax return, etc. for the business year that includes the date of that qualified capital contribution in kind using a blue return, the amount of the reserve for special repairs as of the end of that business year is included in gross profit in calculating the amount of income for that business year.

⑱With regard to the application of the provisions of paragraph (2) to each business year from the business year that includes the date of the qualified capital contribution in kind onward (or, if the business year that includes the date of that qualified capital contribution in kind falls under a consolidated business year, each business year after that consolidated business year) of the corporation receiving a capital contribution in kind referred to in paragraph (15) or Article 82, paragraph (11) of the Supplementary Provisions (excluding one that falls under a consolidated corporation after that qualified capital contribution in kind), the amount of the reserve for special repairs prescribed in paragraph (2) is to include the amount of the reserve for special repairs that that corporation receiving a capital contribution in kind is deemed to have pursuant to the provisions of paragraph (15) or paragraph (11) of that Article. In such a case, with regard to the amount of the reserve for special repairs that that corporation receiving a capital contribution in kind is deemed to have, the phrase "by the number of months in each business year and dividing the result by 48 (or, if that corporation is a small and medium sized enterprise, 120)" in paragraph (2) is deemed to be replaced with "by the number of months in each business year (or, for the business year that includes the date of that qualified capital contribution in kind, the number of months in the period from that date to the end of the business year that includes that date) and dividing the result by the number of months obtained by deducting the number of months in the elapsed period (meaning the period from the date of commencement of the business year first beginning on or after April 1, 2012 (or, if the business year first beginning on or after April 1 of that year falls under a consolidated business year, the date of commencement of that consolidated business year) to the day before the date of that qualified capital contribution in kind) from 48 months (or, if that corporation is a small and medium sized enterprise, 120 months)".