①The provisions of Article 70, paragraphs (1), (2), and (4) (Deduction for Carryover of Net Loss), Article 140, paragraph (5) (Claim to Be Issued a Refund Based on Carryback of Net Loss), and Article 141, paragraph (4) (Claim by an Heir to Be Issued a Refund Based on Carryback of Net Loss) of the new Act (including as applied mutatis mutandis pursuant to Article 166 (Application Mutatis Mutandis to Nonresidents) of the new Act) apply to a Net Loss incurred in each year from 1968 onward, and the provisions then in force continue to govern a Net Loss incurred in each year up to and including 1967.

②With regard to the application of the provisions of Article 140, paragraph (1) or Article 141, paragraph (1) of the new Act (including as applied mutatis mutandis pursuant to Article 166 of the new Act; the same applies hereinafter in this Article) in the case where there is a Net Loss in 1968, the amount of income tax that forms the basis for calculating a refund under those provisions is the amount of income tax calculated by applying the provisions of Article 3, paragraph (2) (Special Provisions on the Calculation of Income Deductions and Tax Amounts for Income Tax for 1967) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act (Act No. 20 of 1967) (including the provisions of Article 90, paragraph (2) (Averaging Taxation on Fluctuating Income and Ad Hoc Income) of the Income Tax Act as amended by that Act, as replaced pursuant to paragraph (1) of that Article).