①The provisions of Article 68-88, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to transactions between a consolidated corporation and a foreign corporation having a permanent establishment that is a foreign affiliate prescribed in that paragraph of that consolidated corporation, in the business years of that foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern transactions between a consolidated corporation and a foreign corporation that is a foreign affiliate prescribed in Article 68-88, paragraph (1) of the Former Act on Special Measures Concerning Taxation of that consolidated corporation, in the business years of that foreign corporation that began before that date.

②The provisions of Article 68-88, paragraph (3) of the New Act on Special Measures Concerning Taxation apply to the amount of donations prescribed in that paragraph that a consolidated corporation expends to a foreign corporation having a permanent establishment that is a foreign affiliate prescribed in paragraph (1) of that Article of that consolidated corporation, in the business years of that foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern the amount of donations prescribed in paragraph (3) of that Article that a consolidated corporation expended to a foreign corporation that is a foreign affiliate prescribed in Article 68-88, paragraph (1) of the Former Act on Special Measures Concerning Taxation of that consolidated corporation, in the business years of that foreign corporation that began before that date.

③The provisions of Article 68-88-2, paragraphs (2) and (5) of the New Act on Special Measures Concerning Taxation apply to a grace period for tax payment under the provisions of paragraph (1) of that Article that is applied for on or after April 1, 2015, and the provisions then in force continue to govern a grace period for tax payment under the provisions of Article 68-88-2, paragraph (1) of the Former Act on Special Measures Concerning Taxation that was applied for before that date.

The provisions then in force continue to govern premiums listed in Article 66-11, paragraph (1), item (iii) of the Former Act on Special Measures Concerning Taxation that a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation paid before the Effective Date.

The provisions of Article 68-107-2 of the New Act on Special Measures Concerning Taxation apply to the calculation of the amount of consolidated foreign-source income prescribed in paragraph (1) of that Article for consolidated business years for which the consolidated corporation's consolidated parent corporation business year begins on or after April 1, 2016.

The provisions then in force continue to govern the amount of distributions of profits of a foreign special purpose trust prescribed in Article 68-110, paragraph (2) of the Former Act on Special Measures Concerning Taxation that a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation received before April 1, 2016.

The provisions then in force continue to govern the amount of distributions of proceeds of a foreign special investment trust prescribed in Article 68-111, paragraph (2) of the Former Act on Special Measures Concerning Taxation that a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation received before April 1, 2016.