①With regard to the application of the provisions of Article 66-6, paragraphs (2) and (4) of the Act on Special Measures Concerning Taxation as Amended for 2022 in the case where, in a business year of a foreign affiliated company prescribed in Article 66-6, paragraph (2), item (i) of the Act on Special Measures Concerning Taxation, there is a consolidated corporation listed in any of the items of Article 68-90, paragraph (1) of the Act on Special Measures Concerning Taxation Before the 2022 Changes pertaining to that foreign affiliated company, the phrase "domestic corporation" in paragraph (2), item (ii), (c), 1. and item (iii), (c), 1. of that Article is deemed to be replaced with "domestic corporation, or consolidated corporation prescribed in Article 2, paragraph (2), item (x)-6 of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 16 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020) that is listed in any of the items of Article 68-90, paragraph (1) of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 16 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020)".

②Where a domestic corporation has, in each consolidated business year, received the application of the provisions of Article 68-90, paragraph (1) of the Act on Special Measures Concerning Taxation Before the 2022 Changes with regard to the amount equivalent to the individually taxable amount prescribed in that paragraph of a foreign affiliated company prescribed in paragraph (2), item (i) of that Article pertaining to that domestic corporation, received the application of the provisions of paragraph (6) of that Article with regard to the amount equivalent to the individually partially taxable amount prescribed in that paragraph of that foreign affiliated company, or received the application of the provisions of paragraph (8) of that Article with regard to the amount equivalent to the individually partially taxable amount for a financial subsidiary, etc. prescribed in that paragraph of that foreign affiliated company, and foreign country's corporate tax (meaning the foreign country's corporate tax prescribed in Article 66-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended for 2022; the same applies hereinafter in this paragraph) is imposed on the income of that foreign affiliated company during the period of each business year beginning after the end of the consolidated business year in which the domestic corporation received that application (or, for the foreign country's corporate tax specified by Cabinet Order prescribed in Article 66-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended for 2022, when specified by Cabinet Order), the provisions of that paragraph apply by deeming that individually taxable amount, that individually partially taxable amount or that individually partially taxable amount for a financial subsidiary, etc. of that foreign affiliated company to be the taxable amount prescribed in Article 66-6, paragraph (1) of the Act on Special Measures Concerning Taxation, the partially taxable amount prescribed in paragraph (6) of that Article or the partially taxable amount for a financial subsidiary, etc. prescribed in paragraph (8) of that Article, of the foreign affiliated company prescribed in Article 66-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended for 2022, and the amount of that foreign country's corporate tax imposed on the income of the foreign affiliated company prescribed in that item (or, for the foreign country's corporate tax specified by Cabinet Order prescribed in Article 66-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended for 2022, the amount specified by Cabinet Order) to be the amount of foreign country's corporate tax imposed on the income of the foreign affiliated company prescribed in Article 66-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended for 2022, respectively.

③With regard to the application of the provisions of Article 66-7, paragraph (2) of the Act on Special Measures Concerning Taxation as Amended for 2022 in the case where the provisions of the preceding paragraph apply, the domestic corporation prescribed in that paragraph is to include the domestic corporation referred to in the preceding paragraph.

④Where a domestic corporation has a consolidated business year that began within ten years before the first day of the business year that includes the day on which it receives the amount of dividend of surplus, etc. (meaning the amount of dividend of surplus, etc. prescribed in Article 66-8, paragraph (1) of the Act on Special Measures Concerning Taxation; the same applies in paragraph (8)) from a foreign corporation prescribed in paragraphs (1) through (3) of that Article, and there is an individually taxed amount (meaning an individually taxed amount prescribed in Article 68-92, paragraph (4), item (ii) of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter through paragraph (6)) for that consolidated business year, then, with regard to the application of the provisions of Article 66-8, paragraph (4) of the Act on Special Measures Concerning Taxation as Amended for 2022, that individually taxed amount is deemed to be the already-taxed amount (meaning an already-taxed amount prescribed in item (ii) of that paragraph; the same applies in the following paragraph and paragraph (6)) for the business year within the preceding ten years prescribed in item (ii) of that paragraph that corresponds to the period of that consolidated business year.

⑤With regard to the application of the provisions of Article 66-8, paragraph (5) of the Act on Special Measures Concerning Taxation as Amended for 2022, the already-taxed amount for the business year within ten years before the merger, etc. (meaning the business year within ten years before the merger, etc. prescribed in item (i) of that paragraph; the same applies hereinafter in this paragraph) of the merged corporation or the corporation making a distribution in kind referred to in item (i) of that paragraph is to include the individually taxed amount for that business year within ten years before the merger, etc., and the already-taxed amount for the business year within ten years before the company split, etc. (meaning the business year within ten years before the company split, etc. prescribed in item (ii) of that paragraph; the same applies hereinafter in this paragraph) of the split corporation, etc. prescribed in paragraph (5), item (ii) of that Article is to include the individually taxed amount for that business year within ten years before the company split, etc.

⑥With regard to the application of the provisions of Article 66-8, paragraph (6) of the Act on Special Measures Concerning Taxation as Amended for 2022, an amount deemed to be the already-taxed amount prescribed in that paragraph is to include an amount deemed to be the individually taxed amount for each consolidated business year within the preceding ten years prescribed in paragraph (4), item (ii) of that Article pursuant to the provisions of Article 68-92, paragraph (6) of the Act on Special Measures Concerning Taxation Before the 2022 Changes.

⑦With regard to the application of the provisions of Article 66-8, paragraph (10) of the Act on Special Measures Concerning Taxation as Amended for 2022, the business year of the other foreign corporation referred to in item (i) of that paragraph to which the provisions of Article 66-6, paragraph (1), (6) or (8) of the Act on Special Measures Concerning Taxation apply is to include the business year of that other foreign corporation to which the provisions of Article 68-90, paragraph (1), (6) or (8) of the Act on Special Measures Concerning Taxation Before the 2022 Changes apply, and the amount for which the domestic corporation referred to in that item has received the application of the provisions of Article 66-8, paragraphs (7) through (9) of the Act on Special Measures Concerning Taxation as Amended for 2022 is to include the amount for which that domestic corporation has received the application of the provisions of Article 68-92, paragraphs (8) through (10) of the Act on Special Measures Concerning Taxation Before the 2022 Changes.

⑧Where a domestic corporation has a consolidated business year that began within two years before the first day of the business year that includes the day on which it receives the amount of dividend of surplus, etc. from a foreign corporation prescribed in Article 66-8, paragraphs (7) through (9) of the Act on Special Measures Concerning Taxation as Amended for 2022, and there is an individual indirectly taxed amount (meaning an individual indirectly taxed amount prescribed in Article 68-92, paragraph (11), item (ii), (b) of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter in this paragraph) for that consolidated business year, then, with regard to the application of the provisions of Article 66-8, paragraph (10) of the Act on Special Measures Concerning Taxation as Amended for 2022, that individual indirectly taxed amount is deemed to be the indirectly taxed amount prescribed in item (ii), (b) of that paragraph for the business year within the preceding two years prescribed in item (i) of that paragraph that corresponds to the period of that consolidated business year. In this case, the phrase "through the preceding paragraph" in paragraph (11) of that Article is deemed to be replaced with "through paragraph (9) and the preceding paragraph (including as applied with the deeming under the first sentence of Article 126, paragraph (8) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020))".

⑨The provisions of paragraphs (5) and (6) apply mutatis mutandis in the case where the provisions of paragraphs (5) and (6) of Article 66-8 of the Act on Special Measures Concerning Taxation as Amended for 2022 are applied mutatis mutandis pursuant to paragraph (11) of that Article. In this case, the phrase "business year within ten years before the merger, etc. (meaning the business year within ten years before the merger, etc. prescribed in item (i) of that paragraph" in paragraph (5) is deemed to be replaced with "business year within two years before the merger, etc. (meaning the business year within two years before the merger, etc. prescribed in paragraph (5), item (i) of that Article as replaced pursuant to paragraph (11) of that Article"; the phrase "already-taxed amount is to include the individually taxed amount for that business year within ten years before the merger, etc." with "indirect dividends, etc. (meaning the indirect dividends, etc. prescribed in Article 66-8, paragraph (10), item (i) of the Act on Special Measures Concerning Taxation as Amended for 2022; the same applies hereinafter in this paragraph and the following paragraph) or indirectly taxed amount (meaning the indirectly taxed amount prescribed in paragraph (10), item (ii), (b) of that Article; the same applies hereinafter in this paragraph and the following paragraph) is to include the individual indirect dividends, etc. (meaning the individual indirect dividends, etc. prescribed in Article 68-92, paragraph (11), item (i) of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter in this paragraph and the following paragraph) or individual indirectly taxed amount (meaning the individual indirectly taxed amount prescribed in Article 68-92, paragraph (11), item (ii), (b) of the Act on Special Measures Concerning Taxation Before the 2022 Changes; the same applies hereinafter in this paragraph and the following paragraph) for that business year within two years before the merger, etc."; the phrase "business year within ten years before the company split, etc. of the split corporation, etc. prescribed in paragraph (5), item (ii) of that Article (meaning the business year within ten years before the company split, etc. prescribed in that item" with "business year within two years before the company split, etc. of the split corporation, etc. prescribed in paragraph (5), item (ii) of Article 66-8 of the Act on Special Measures Concerning Taxation as Amended for 2022 as applied mutatis mutandis pursuant to paragraph (11) of that Article (meaning the business year within two years before the company split, etc. prescribed in paragraph (5), item (ii) of Article 66-8 of the Act on Special Measures Concerning Taxation as Amended for 2022 as replaced pursuant to paragraph (11) of that Article"; the phrase "already-taxed amount is to include the individually taxed amount for that business year within ten years before the company split, etc." with "indirect dividends, etc. or indirectly taxed amount is to include the individual indirect dividends, etc. or individual indirectly taxed amount for that business year within two years before the company split, etc."; the phrase "the already-taxed amount prescribed in that paragraph" in paragraph (6) with "the indirect dividends, etc. or indirectly taxed amount prescribed in paragraph (6) of Article 66-8 of the Act on Special Measures Concerning Taxation as Amended for 2022 as replaced pursuant to paragraph (11) of that Article"; the phrase "Article 68-92, paragraph (6)" with "paragraph (6) of Article 68-92 as applied mutatis mutandis pursuant to paragraph (13) of that Article"; and the phrase "the individually taxed amount for each consolidated business year within the preceding ten years prescribed in paragraph (4), item (ii) of that Article" with "the individual indirect dividends, etc. for each consolidated business year, etc. within the preceding two years prescribed in Article 68-92, paragraph (11), item (i) of the Act on Special Measures Concerning Taxation Before the 2022 Changes or the individual indirectly taxed amount for each consolidated business year within the preceding two years prescribed in item (ii), (b) of that paragraph".

⑩With regard to the application of the provisions of Article 66-8, paragraph (12) of the Act on Special Measures Concerning Taxation as Amended for 2022 in the case where, among the business years of a domestic corporation that began before April 1, 2022 (including a business year of a consolidated subsidiary corporation whose consolidated parent corporation business year (meaning a consolidated parent corporation business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act; the same applies in paragraph (7) of the following Article) began before that date), there is one that falls under a consolidated business year, the phrase "business years pertaining to" in that paragraph is deemed to be replaced with "business years or consolidated business years (meaning consolidated business years prescribed in Article 2, paragraph (2), item (xix) of the Act on Special Measures Concerning Taxation prior to the amendment by the provisions of Article 16 of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; hereinafter referred to as the '2020 Amendment Act' in this paragraph); the same applies hereinafter in this paragraph) pertaining to", the phrase "business year onward" with "business year or consolidated business year onward", and the phrase "has been filed" with "or a consolidated tax return prescribed in Article 2, item (xxxii) of the Corporation Tax Act prior to the amendment by the provisions of Article 3 of the 2020 Amendment Act for each consolidated business year has been filed".