①The valuation gain (meaning, in the case where the value at that time exceeds the book value at that time, the amount of the excess) or the valuation loss (meaning, in the case where the book value at that time exceeds the value at that time, the amount of the excess) of the assets evaluated by fair value (meaning Fixed Assets, land (including any right on land and excluding land that falls under the category of Fixed Assets), securities, monetary claims and deferred assets (excluding those of these assets specified by Cabinet Order as not being suitable for the booking of valuation gains or losses)) held as of the end of the business year immediately before the start of group tax sharing (meaning the business year of the domestic corporation containing the day preceding the first day of the first group tax sharing business year (in the case where the domestic corporation is a corporation subject to fair valuation prescribed in Article 64-9, paragraph (10), item (i), the last day of the first group tax sharing business year); the same applies hereinafter in this paragraph and the following paragraph) by a domestic corporation that obtains group tax sharing approval (limited to the parent corporation prescribed in Article 64-9, paragraph (1) (Group Tax Sharing Approval) (hereinafter referred to as the "parent corporation" in this paragraph and the following paragraph) and those that have, with the parent corporation, a full controlling interest held by the parent corporation (limited to the relationship specified by Cabinet Order prescribed in paragraph (1) of that Article; hereinafter the same applies in this paragraph and the following Article) as of the start of the first group tax sharing business year (meaning the business year that first ends on or after the day on which the group tax sharing approval becomes effective; hereinafter the same applies in this paragraph) of the parent corporation, and excluding the following) is included in gross profits or deductible expenses, when calculating the amount of income for the business year immediately before the start of group tax sharing:

②The valuation gain (meaning, in the case where the value at that time exceeds the book value at that time, the amount of the excess) or the valuation loss (meaning, in the case where the book value at that time exceeds the value at that time, the amount of the excess) of the shares or capital contributions (in the case where the provisions of the preceding paragraph apply to the corporation holding shares, etc., excluding those that fall under the category of assets evaluated by fair value prescribed in that paragraph) held, as of the end of the business year immediately before the start of group tax sharing of the domestic corporation prescribed in the preceding paragraph (excluding a corporation specified by Cabinet Order as a corporation not subject to the provisions of Article 64-5 (Aggregation of Profits and Losses), and the parent corporation), by a domestic corporation that holds shares of or capital contributions to that domestic corporation (hereinafter referred to as the "corporation holding shares, etc." in this paragraph) is included in gross profits or deductible expenses, when calculating the amount of income for the business year of the corporation holding shares, etc. containing the last day of the business year immediately before the start of group tax sharing.

③The book value of assets whose valuation gain or valuation loss prescribed in the preceding two paragraphs has been included in gross profits or deductible expenses under those provisions and other necessary matters concerning the application of those provisions are specified by Cabinet Order.