Article 145-6

一a foreign corporation that is a constituent entity (meaning a constituent entity prescribed in Article 82, item (xiii) (Definitions); the same applies hereinafter in this item) having, in each covered fiscal year, a permanent establishment, etc. (meaning a permanent establishment, etc. prescribed in item (vi) of that Article, limited to one whose country of location prescribed in item (vii) of that Article is Japan; the same applies hereinafter in this Article) belonging to a specified multinational enterprise group, etc. (meaning a specified multinational enterprise group, etc. prescribed in item (iv) of that Article; the same applies hereinafter in this paragraph), or a foreign corporation that was a constituent entity having a permanent establishment, etc. belonging to the specified multinational enterprise group, etc. in a past covered fiscal year (meaning a past covered fiscal year prescribed in item (xxxii) of that Article; the same applies in the following item) and is not the constituent entity in the covered fiscal year: the domestic minimum tax amount pertaining to the permanent establishment, etc. of a constituent entity for the covered fiscal year; and

二a foreign corporation that is a jointly controlled entity, etc. (meaning a jointly controlled entity, etc. prescribed in Article 82, item (xv); the same applies hereinafter in this item) having, in each covered fiscal year, a permanent establishment, etc. pertaining to a specified multinational enterprise group, etc., or a foreign corporation that was a jointly controlled entity, etc. having a permanent establishment, etc. pertaining to the specified multinational enterprise group, etc. in a past covered fiscal year and is not the jointly controlled entity, etc. in the covered fiscal year: the domestic minimum tax amount pertaining to the permanent establishment, etc. of a jointly controlled entity, etc. for the covered fiscal year.