Article 177Special Provisions on Taxation of Dividends and Similar Income Related to Shares, etc. of Wholly Owned Subsidiaries
第百七十七条（完全子法人株式等に係る配当等の課税の特例）
The provisions of Article 7, paragraph (1), item (iv) (Scope of Taxable Income), Article 174 (Tax Base for a Domestic Corporation's Income Taxes), and Article 175 (Tax Rates for a Domestic Corporation's Income Taxes) do not apply to dividends and similar income as prescribed in Article 24, paragraph (1) (Dividend Income) which a Domestic Corporation (excluding general incorporated associations and general incorporated foundations (other than incorporated public interest associations and incorporated public interest foundations), worker cooperatives, Associations or Foundations without Legal Personality, and those prescribed by Cabinet Order which are deemed to be public interest corporations, etc. as prescribed in Article 2, item (vi) (Definitions) of the Corporation Tax Act by an Act other than the Corporation Tax Act (referred to as "general incorporated association or similar corporation" in the following paragraph); hereinafter the same applies in this Article) is paid and which relate to shares or similar interests (meaning shares or similar interests as prescribed in paragraph (1) of Article 23 of that Act, limited to those which the Domestic Corporation holds in its own name; the same applies in the following paragraph) that fall under shares or similar interests of wholly owned subsidiaries of the Domestic Corporation as prescribed in Article 23, paragraph (5) (Exclusion of Dividends Received from Gross Profits) of that Act.
第七条第一項第四号（課税所得の範囲）、第百七十四条（内国法人に係る所得税の課税標準）及び第百七十五条（内国法人に係る所得税の税率）の規定は、内国法人（一般社団法人及び一般財団法人（公益社団法人及び公益財団法人を除く。）、労働者協同組合、人格のない社団等並びに法人税法以外の法律によつて法人税法第二条第六号（定義）に規定する公益法人等とみなされているもので政令で定めるもの（次項において「一般社団法人等」という。）を除く。以下この条において同じ。）が支払を受ける当該内国法人の同法第二十三条第五項（受取配当等の益金不算入）に規定する完全子法人株式等に該当する株式等（同条第一項に規定する株式等をいい、当該内国法人が自己の名義をもつて有するものに限る。次項において同じ。）に係る第二十四条第一項（配当所得）に規定する配当等については、適用しない。
The provisions of Article 7, paragraph (1), item (iv), Article 174, and Article 175 do not apply to dividends and similar income as prescribed in Article 24, paragraph (1) which a Domestic Corporation (limited to a Domestic Corporation in a case prescribed by Cabinet Order as one in which the Domestic Corporation holds shares or similar interests whose number or amount exceeds one third of the total number or total amount of the shares issued or capital contributions (excluding its own shares or similar interests held by the other Domestic Corporation) of another Domestic Corporation (excluding general incorporated associations or similar corporations)) is paid and which relate to shares or similar interests of that other Domestic Corporation (excluding shares or similar interests that fall under shares or similar interests of wholly owned subsidiaries as prescribed in the preceding paragraph).
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Domestic Corporation
「内国法人」
A corporation whose head office or principal office is in Japan.
Defined inArticle 2, paragraph (1), item (vi)· applies throughout the law
Association or Foundation without Legal Personality
「人格のない社団等」
An association or foundation that is not a corporation but has a designated representative or administrator.
Defined inArticle 2, paragraph (1), item (viii)· applies throughout the law
dividends and similar incomemachine translation
「配当等」
Dividends of surplus, dividends of profits, distributions of surplus, distributions of money by investment corporations, interest on foundation funds, and distributions from investment trusts (other than bond ones) and specified trusts issuing beneficiary certificates, as listed in Article 24, paragraph (1) on dividend income.
Short name set inArticle 24, paragraph (1)· applies only in this article
general incorporated association or similar corporationmachine translation
「一般社団法人等」
A general incorporated association or general incorporated foundation that is not a public interest one, a workers' cooperative, an association or foundation without legal personality, or a body a Cabinet Order (政令) lists that a law other than the Corporation Tax Act treats as a public interest corporation — the domestic corporations left out of the relief in Article 177 for dividends on the shares of wholly owned subsidiaries.
Short name set inArticle 177, paragraph (1)· applies only in this provision and in Article 177, paragraph (2)
share or similar interestmachine translation
「株式等」
In Article 177, paragraphs (1) and (2), shares or equity interests (株式又は出資) as Article 23, paragraph (1) of the Corporation Tax Act uses the term, limited to those the domestic corporation holds in its own name.
Defined inArticle 177, paragraph (1)· applies only in this provision and in Article 177, paragraph (2)