With regard to the application of the provisions of Article 59-2 of the New Act on Special Measures Concerning Taxation for a business year beginning during the period from the Effective Date to March 31, 2024 of a corporation that receives the certification under Article 35, paragraph (3) of the Marine Transportation Act (Act No. 187 of 1949) on or after the Effective Date, the phrase "the commencement date" in paragraph (2) of that Article is deemed to be replaced with "the day on which two months have elapsed on or after the commencement date".

The provisions of Article 61-3, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to specified agricultural machinery, etc. prescribed in that paragraph that a corporation acquires, manufactures or constructs on or after the Effective Date, and the provisions then in force continue to govern specified agricultural machinery, etc. prescribed in Article 61-3, paragraph (1) of the Former Act on Special Measures Concerning Taxation that a corporation acquired, manufactured or constructed before the Effective Date.

①The provisions then in force continue to govern, in the case where a corporation transferred assets listed in the left-hand column of item (i) of the table in Article 65-7, paragraph (1) of the Former Act on Special Measures Concerning Taxation before the Effective Date, the assets listed in the right-hand column of that item that it acquired (including constructing and manufacturing; the same applies hereinafter in this Article) before the Effective Date or the assets listed in that column that it acquires on or after the Effective Date, and the special account or special account during the year under Article 65-8, paragraph (1) or (2) of the Former Act on Special Measures Concerning Taxation pertaining to those assets.

②The provisions of Articles 65-7 through 65-9 of the Act on Special Measures Concerning Taxation as amended by the provisions of Article 10 (excluding the amending provisions listed in Article 1, item (iv), (d) of the Supplementary Provisions) (hereinafter referred to as the "Act on Special Measures Concerning Taxation as Amended in 2023" in this paragraph) (limited to the part pertaining to items (i), (iii) and (iv) of the table in Article 65-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended in 2023) apply to the assets in the case where a corporation transfers assets listed in the left-hand column of item (i), (iii) or (iv) of that table on or after the Effective Date and acquires assets listed in the right-hand column of those items on or after the Effective Date, and to the special account or special account during the year under Article 65-8, paragraph (1) or (2) of the Act on Special Measures Concerning Taxation as Amended in 2023 pertaining to those assets, and the provisions then in force continue to govern, in the case where a corporation transferred assets listed in the left-hand column of item (ii), (iv) or (v) of the table in Article 65-7, paragraph (1) of the Former Act on Special Measures Concerning Taxation before the Effective Date, the assets listed in the right-hand column of those items that it acquired before the Effective Date or the assets listed in the right-hand column of those items that it acquires on or after the Effective Date, and the special account or special account during the year under Article 65-8, paragraph (1) or (2) of the Former Act on Special Measures Concerning Taxation pertaining to those assets, as well as, in the case where a corporation transfers assets listed in the left-hand column of those items on or after the Effective Date, the assets listed in the right-hand column of those items that it acquired before the Effective Date.

③The provisions of Articles 65-7 through 65-9 of the Act on Special Measures Concerning Taxation as amended by the provisions of Article 10 (limited to the amending provisions listed in Article 1, item (iv), (d) of the Supplementary Provisions; the same applies hereinafter in this paragraph) (hereinafter referred to as the "Act on Special Measures Concerning Taxation as Amended in 2024" in this paragraph) (limited to the part pertaining to the notification under Article 65-7, paragraphs (1) and (9) of the Act on Special Measures Concerning Taxation as Amended in 2024) apply to the assets in the case where a corporation transfers assets listed in the left-hand column of any item of the table in Article 65-7, paragraph (1) of the Act on Special Measures Concerning Taxation as Amended in 2024 on or after April 1, 2024 and acquires assets listed in the right-hand column of that item on or after that date, and the provisions then in force continue to govern, in the case where a corporation transferred assets listed in the left-hand column of any item of the table in Article 65-7, paragraph (1) of the Act on Special Measures Concerning Taxation before the amendment by the provisions of Article 10 before that date, the assets listed in the right-hand column of that item that it acquired before that date or the assets listed in the right-hand column of that item that it acquires on or after that date, as well as, in the case where a corporation transfers assets listed in the left-hand column of any item of that table on or after that date, the assets listed in the right-hand column of that item that it acquired before that date.

The provisions of Article 66-2, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to a partial share exchange carried out on or after October 1, 2023, and the provisions then in force continue to govern a partial share exchange carried out before that date.

①The provisions of Article 66-6, paragraphs (5), (11) and (12) of the New Act on Special Measures Concerning Taxation apply where 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 and the partially taxable amount for a financial subsidiary, etc. prescribed in paragraph (8) of that Article are calculated for business years beginning on or after April 1, 2024 of a domestic corporation listed in the items of paragraph (1) of that Article, and the provisions then in force continue to govern the calculation of the taxable amount prescribed in that paragraph, the partially taxable amount prescribed in paragraph (6) of that Article and the partially taxable amount for a financial subsidiary, etc. prescribed in paragraph (8) of that Article for business years beginning before that date of a domestic corporation listed in the items of paragraph (1) of that Article.

②The provisions of Article 66-9-2, paragraph (5) and paragraphs (11) through (13) of the New Act on Special Measures Concerning Taxation apply where the taxable amount prescribed in Article 66-9-2, paragraph (1) of the Act on Special Measures Concerning Taxation, the partially taxable amount prescribed in paragraph (6) of that Article and the partially taxable amount for a financial affiliated corporation prescribed in paragraph (8) of that Article are calculated for business years beginning on or after April 1, 2024 of a domestic corporation that is a specially-related shareholder, etc. prescribed in paragraph (1) of that Article, and the provisions then in force continue to govern the calculation of the taxable amount prescribed in that paragraph, the partially taxable amount prescribed in paragraph (6) of that Article and the partially taxable amount for a financial affiliated corporation prescribed in paragraph (8) of that Article for business years beginning before that date of a domestic corporation that is a specially-related shareholder, etc. prescribed in paragraph (1) of that Article.

The provisions then in force continue to govern the amount of loss prescribed in Article 2, paragraph (2), item (xxi) of the Act on Special Measures Concerning Taxation (including an amount deemed to be the amount of loss prescribed in Article 2, paragraph (2), item (xxi) of the Act on Special Measures Concerning Taxation pursuant to the provisions of Article 20, paragraph (1) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020)) that arose in a business year beginning before the Effective Date of a corporation (including, where that corporation is a group tax sharing corporation, the other group tax sharing corporations) that received, on or before the day on which one year has elapsed as prescribed in Article 66-11-4, paragraph (1) of the Former Act on Special Measures Concerning Taxation, the certification under Article 21-15, paragraph (1) of the Act on Strengthening Industrial Competitiveness (Act No. 98 of 2013) before the amendment by the provisions of Article 1 of the Act Partially Amending the Act on Strengthening Industrial Competitiveness, etc. to Promote the Creation of New Businesses and Investment in Industry (Act No. 45 of 2024).

The provisions of Article 66-13 of the New Act on Special Measures Concerning Taxation apply to shares acquired by a corporation on or after the Effective Date, and the provisions then in force continue to govern shares acquired by a corporation before the Effective Date.

①In the case of acquiring by gift a specified planned forest prescribed in Article 69-5, paragraph (1) of the New Act on Special Measures Concerning Taxation to which the provisions of Article 21-9, paragraph (3) of the Inheritance Tax Act (including as applied mutatis mutandis pursuant to Article 70-2-6, paragraph (1), Article 70-2-7, paragraph (1) (including as applied mutatis mutandis pursuant to Article 70-2-8 of the Act on Special Measures Concerning Taxation) or Article 70-3, paragraph (1) of the Act on Special Measures Concerning Taxation) apply, the provisions of Article 69-5, paragraph (1) of the New Act on Special Measures Concerning Taxation apply to inheritance tax pertaining to that specified planned forest acquired by gift on or after January 1, 2024.

②The provisions of Article 70-2-2 of the New Act on Special Measures Concerning Taxation apply to inheritance tax or gift tax on beneficial interests in a trust, etc. pertaining to an individual (hereinafter referred to as a "person subject to the new Act" in this paragraph) who acquires, on or after the Effective Date, a beneficial interest in a trust, money, or monies, etc. prescribed in paragraph (1) of that Article (hereinafter referred to as "beneficial interests in a trust, etc." in this paragraph), and the provisions then in force continue to govern inheritance tax or gift tax on beneficial interests in a trust, etc. pertaining to an individual (excluding a person subject to the new Act) who acquired beneficial interests in a trust, etc. before the Effective Date. In this case, necessary matters concerning the calculation of the remaining managed balance prescribed in paragraph (12), item (i) of that Article pertaining to a person subject to the new Act who acquired beneficial interests in a trust, etc. before the Effective Date, and of the remaining balance prescribed in Article 70-2-2, paragraph (17) of the New Act on Special Measures Concerning Taxation that is deemed, pursuant to the provisions of paragraph (17), item (ii) of that Article pertaining to that person subject to the new Act, to be general gift property prescribed in Article 70-2-5, paragraph (3) of the Act on Special Measures Concerning Taxation (referred to as "general gift property" in the following paragraph), are specified by Cabinet Order.

③The provisions of Article 70-2-3, paragraph (14) of the New Act on Special Measures Concerning Taxation apply to gift tax on beneficial interests in a trust, etc. pertaining to an individual (hereinafter referred to as a "person subject to the new Act" in this paragraph) who acquires, on or after the Effective Date, a beneficial interest in a trust, money, or monies, etc. prescribed in paragraph (1) of that Article (hereinafter referred to as "beneficial interests in a trust, etc." in this paragraph), and the provisions then in force continue to govern gift tax on beneficial interests in a trust, etc. pertaining to an individual (excluding a person subject to the new Act) who acquired beneficial interests in a trust, etc. before the Effective Date. In this case, necessary matters concerning the calculation of the remaining balance prescribed in paragraph (14) of that Article that is deemed to be general gift property pursuant to the provisions of item (ii) of that paragraph pertaining to a person subject to the new Act who acquired beneficial interests in a trust, etc. before the Effective Date are specified by Cabinet Order.

④The provisions of Article 70-3-2 of the New Act on Special Measures Concerning Taxation apply to gift tax on property acquired by gift on or after January 1, 2024.

⑤The provisions of Article 70-3-3 of the New Act on Special Measures Concerning Taxation apply where the land or building referred to in paragraph (1) of that Article suffers damage from a disaster prescribed in that paragraph on or after January 1, 2024. In this case, with regard to inheritance tax on that land or building acquired by gift before that date, the provisions of Article 21-15, paragraph (1) or Article 21-16, paragraph (3) of the New Inheritance Tax Act apply, notwithstanding the provisions of Article 19, paragraph (1) of the Supplementary Provisions.

⑥The provisions of Article 70-6-8, paragraph (2), item (iii), (b) of the New Act on Special Measures Concerning Taxation apply to gift tax on specified business assets (meaning specified business assets prescribed in Article 70-6-8, paragraph (2), item (i) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) acquired by gift on or after January 1, 2024, and the provisions then in force continue to govern gift tax on specified business assets acquired by gift before that date.

⑦The provisions of Article 70-7, paragraph (2), item (v), (b) and Article 70-7-5, paragraph (2), item (viii), (b) of the New Act on Special Measures Concerning Taxation apply to gift tax on unlisted shares or similar interests (meaning unlisted shares or similar interests prescribed in Article 70-7, paragraph (2), item (ii) of the Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) acquired by gift on or after January 1, 2024, and the provisions then in force continue to govern gift tax on unlisted shares or similar interests acquired by gift before that date.

⑧The provisions of Article 70-7-9, paragraph (14) of the New Act on Special Measures Concerning Taxation (including as applied mutatis mutandis pursuant to Article 70-7-12, paragraph (14) of the New Act on Special Measures Concerning Taxation; the same applies hereinafter in this paragraph) apply where, on or after the Effective Date, the certification under Article 10-4, paragraph (1) of the Supplementary Provisions of the 2006 Medical Care Act, etc. Amendment Act prescribed in paragraph (2), item (i) of that Article is given for a change to the certified transition plan of a certified medical care corporation prescribed in Article 70-7-9, paragraph (14) of the New Act on Special Measures Concerning Taxation.