Article 82-3

一a constituent entity (excluding one that falls under a permanent establishment, etc.): the amount calculated as specified in each of the following for the categories of constituent entity listed therein:

イa constituent entity (excluding one listed in (b)) whose ownership interests are directly or indirectly held by that domestic corporation (limited to the ultimate parent company, etc., an intermediate parent company, etc. (excluding an intermediate parent company, etc. in the case where there is an ultimate parent company, etc. on which corporation tax on the international minimum tax amount for each covered fiscal year pertaining to that constituent entity, or a tax equivalent thereto in a foreign country, is to be imposed, or anything else specified by Cabinet Order; the same applies in (b) and the following item) or a partially-owned parent entity (excluding that partially-owned parent entity in the case where another partially-owned parent entity on which corporation tax on the international minimum tax amount for each covered fiscal year pertaining to that constituent entity, or a tax equivalent thereto in a foreign country, is to be imposed directly or indirectly holds all of the interests in that partially-owned parent entity; the same applies in (b) and that item) of that specified multinational enterprise group, etc., and excluding one whose country of location is not Japan; hereinafter the same applies in this item and the following item): the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that constituent entity by the attribution ratio (meaning the ratio calculated pursuant to the provisions of Cabinet Order as the ratio attributable to that domestic corporation, taking into account ownership interests and other circumstances; the same applies in (b));

ロa constituent entity whose ownership interests are indirectly held by that domestic corporation through another constituent entity (limited to that constituent entity in the case where that other constituent entity (limited to an intermediate parent company, etc. or a partially-owned parent entity of that constituent entity) has the international minimum tax amount, etc. (meaning the international minimum tax amount for that covered fiscal year and its equivalent in a foreign country; hereinafter the same applies in this paragraph) of that constituent entity for that covered fiscal year): the remaining amount after deducting, from the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that constituent entity by the attribution ratio, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of that calculated amount that is attributable to that other constituent entity;

二a constituent entity that falls under a permanent establishment, etc.: the amount calculated as specified in each of the following for the categories of permanent establishment, etc. listed therein:

イa permanent establishment, etc. of that domestic corporation: the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by 100 percent;

ロa permanent establishment, etc. of a constituent entity whose ownership interests are directly or indirectly held by that domestic corporation (excluding those listed in (c) and (d)): the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by the attribution ratio (meaning the ratio calculated pursuant to the provisions of Cabinet Order as the ratio attributable to that domestic corporation, taking into account ownership interests and other circumstances; hereinafter the same applies in this item);

ハa permanent establishment, etc. of a constituent entity whose ownership interests are directly or indirectly held by that domestic corporation (limited to that permanent establishment, etc. in the case where that constituent entity (limited to an intermediate parent company, etc. or a partially-owned parent entity of that permanent establishment, etc.) has the international minimum tax amount, etc. for that covered fiscal year of that permanent establishment, etc.): the remaining amount after deducting, from the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by the attribution ratio, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of that calculated amount that is attributable to that constituent entity;

ニa permanent establishment, etc. of a constituent entity whose ownership interests are indirectly held by that domestic corporation through another constituent entity (limited to that permanent establishment, etc. in the case where that other constituent entity (limited to an intermediate parent company, etc. or a partially-owned parent entity of that constituent entity) has the international minimum tax amount, etc. for that covered fiscal year of that permanent establishment, etc., and excluding one listed in (c)): the remaining amount after deducting, from the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by the attribution ratio, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of that calculated amount that is attributable to that other constituent entity;

三a jointly controlled entity, etc. (excluding one listed in the following item): the amount calculated as specified in each of the following for the categories of jointly controlled entity, etc. listed therein:

イa jointly controlled entity, etc. (excluding one listed in (b)) whose ownership interests are directly or indirectly held by that domestic corporation (limited to the ultimate parent company, etc., an intermediate parent company, etc. (excluding an intermediate parent company, etc. in the case where there is an ultimate parent company, etc. on which corporation tax on the international minimum tax amount for each covered fiscal year pertaining to that jointly controlled entity, etc., or a tax equivalent thereto in a foreign country, is to be imposed, or anything else specified by Cabinet Order; the same applies in (b) and the following item) or a partially-owned parent entity (excluding that partially-owned parent entity in the case where another partially-owned parent entity on which corporation tax on the international minimum tax amount for each covered fiscal year pertaining to that jointly controlled entity, etc., or a tax equivalent thereto in a foreign country, is to be imposed directly or indirectly holds all of the interests in that partially-owned parent entity; the same applies in (b) and that item) of that specified multinational enterprise group, etc., and excluding one whose country of location is not Japan; hereinafter the same applies in this item and the following item): the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that jointly controlled entity, etc. by the attribution ratio (meaning the ratio calculated pursuant to the provisions of Cabinet Order as the ratio attributable to that domestic corporation, taking into account ownership interests and other circumstances; the same applies in (b));

ロa jointly controlled entity, etc. whose ownership interests are indirectly held by that domestic corporation through a constituent entity (limited to that jointly controlled entity, etc. in the case where that constituent entity (limited to an intermediate parent company, etc. or a partially-owned parent entity of that jointly controlled entity, etc.) has the international minimum tax amount, etc. for that covered fiscal year of that jointly controlled entity, etc.): the remaining amount after deducting, from the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that jointly controlled entity, etc. by the attribution ratio, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of that calculated amount that is attributable to that constituent entity;

四a jointly controlled entity, etc. (limited to one listed in Article 82, item (xv), (c) (Definitions)): the amount calculated as specified in each of the following for the categories of permanent establishment, etc. listed therein:

イa permanent establishment, etc. of a jointly controlled entity, etc. whose ownership interests are directly or indirectly held by that domestic corporation (excluding one listed in (b)): the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by the attribution ratio (meaning the ratio calculated pursuant to the provisions of Cabinet Order as the ratio attributable to that domestic corporation, taking into account ownership interests and other circumstances; the same applies in (b));

ロa permanent establishment, etc. of a jointly controlled entity, etc. whose ownership interests are indirectly held by that domestic corporation through a constituent entity (limited to that permanent establishment, etc. in the case where that constituent entity (limited to an intermediate parent company, etc. or a partially-owned parent entity of that permanent establishment, etc.) has the international minimum tax amount, etc. for that covered fiscal year of that permanent establishment, etc.): the remaining amount after deducting, from the amount calculated by multiplying the international minimum tax amount by entity for that covered fiscal year of that permanent establishment, etc. by the attribution ratio, the amount calculated pursuant to the provisions of Cabinet Order as the amount of the portion of that calculated amount that is attributable to that constituent entity.

一in the case where the jurisdictional effective tax rate prescribed in (a), (3) in the country of location of a constituent entity (excluding a stateless constituent entity; hereinafter the same applies up to item (iii)) belonging to a specified multinational enterprise group, etc. for each covered fiscal year is less than the base tax rate, and there is an amount of jurisdictional group net income prescribed in (a), (1) of that specified multinational enterprise group, etc. pertaining to that country of location in that covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c):

イthe current jurisdictional international minimum tax amount pertaining to that country of location for that covered fiscal year (meaning the amount calculated by multiplying the remaining amount after deducting the amount listed in (2) from the amount listed in (1) by the ratio listed in (3); the same applies in (b)):

（１）the amount of jurisdictional group net income (meaning the remaining amount after deducting the amount listed in (ii) from the amount listed in (i); hereinafter the same applies up to item (iii)):

（ｉ）the sum of the individual computed income for that covered fiscal year of all constituent entities whose country of location is that country of location;

（ｉｉ）the sum of the individual computed loss for that covered fiscal year of all constituent entities whose country of location is that country of location;

（２）the sum of the following amounts:

（ｉ）the amount equivalent to 5 percent of the amount specified by Cabinet Order as the amount of salaries, wages, remuneration, annual allowances, bonuses or other payments of a similar nature, or other expenses, for that covered fiscal year of all constituent entities whose country of location is that country of location;

（ｉｉ）the amount equivalent to 5 percent of the amount specified by Cabinet Order as the amount of tangible fixed assets or other assets for that covered fiscal year of all constituent entities whose country of location is that country of location;

（３）the ratio obtained by deducting, from the base tax rate, the jurisdictional effective tax rate in that country of location for that covered fiscal year (meaning the ratio that the amount listed in (i) (in the case where the amount listed in (i) for that covered fiscal year exceeds zero and there is an amount of jurisdictional group net income pertaining to that country of location in that covered fiscal year, if there is a past covered fiscal year for which the amount listed in (i) pertaining to that country of location is less than zero, the remaining amount after deducting the amount specified by Cabinet Order as the portion carried forward to that covered fiscal year out of the amount of the portion by which the amount listed in (i) for that past covered fiscal year falls below zero, and in the case where the amount listed in (i) for that covered fiscal year is less than zero, zero) accounts for in the amount listed in (ii); the same applies in the following item):

（ｉ）the jurisdictional adjusted covered tax amount (meaning the sum of the adjusted covered taxes for that covered fiscal year of all constituent entities whose country of location is that country of location; the same applies in item (iii));

（ｉｉ）the amount of jurisdictional group net income;

ロthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year (meaning the sum of the amounts specified by Cabinet Order as the amounts by which the current jurisdictional international minimum tax amount pertaining to the country of location of a constituent entity for a past covered fiscal year fell short; the same applies in (a) of the following item and (a) of item (iii));

ハthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year (meaning the amount specified by Cabinet Order as the international minimum tax amount corresponding to the portion of the individual computed income pertaining to that constituent entity (limited to an investment entity, etc.) that was not distributed to other constituent entities; the same applies in (b) of the following item and (b) of item (iii));

ニthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

二in the case where the jurisdictional effective tax rate in the country of location of a constituent entity belonging to a specified multinational enterprise group, etc. for each covered fiscal year is the base tax rate or more, and there is an amount of jurisdictional group net income of that specified multinational enterprise group, etc. pertaining to that country of location in that covered fiscal year: the remaining amount after deducting the amount listed in (c) from the sum of the amounts listed in (a) and (b):

イthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year;

ロthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year;

ハthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

三in the case where there is no amount of jurisdictional group net income of a specified multinational enterprise group, etc. pertaining to the country of location of a constituent entity belonging to that specified multinational enterprise group, etc. in each covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) and (b) (if, where the jurisdictional adjusted covered tax amount for that covered fiscal year is less than zero, the amount by which it falls below zero exceeds the specified jurisdictional adjusted covered tax amount prescribed in (c) for that covered fiscal year, the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c)):

イthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year;

ロthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year;

ハthe remaining amount after deducting, from the amount by which the jurisdictional adjusted covered tax amount for that covered fiscal year falls below zero where it is less than zero, the specified jurisdictional adjusted covered tax amount pertaining to that country of location for that covered fiscal year (meaning the amount calculated by multiplying the remaining amount after deducting the amount listed in (2) from the amount listed in (1) by the base tax rate):

（１）the sum of the individual computed loss for that covered fiscal year of all constituent entities whose country of location is that country of location;

（２）the sum of the individual computed income for that covered fiscal year of all constituent entities whose country of location is that country of location;

ニthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

四in the case where the stateless constituent entity effective tax rate of a stateless constituent entity belonging to a specified multinational enterprise group, etc. for each covered fiscal year (meaning the ratio that the adjusted covered taxes for that covered fiscal year (in the case where the adjusted covered taxes for that covered fiscal year exceed zero and there is individual computed income of that stateless constituent entity in that covered fiscal year, if there is a past covered fiscal year for which the adjusted covered taxes are less than zero, the remaining amount after deducting the amount specified by Cabinet Order as the portion carried forward to that covered fiscal year out of the amount of the portion by which the adjusted covered taxes for that past covered fiscal year fall below zero, and in the case where the adjusted covered taxes for that covered fiscal year are less than zero, zero) account for in the individual computed income for that covered fiscal year; the same applies in (a), (2) and the following item) is less than the base tax rate, and there is individual computed income of that stateless constituent entity in that covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c) for that stateless constituent entity:

イthe current international minimum tax amount for that covered fiscal year (meaning the amount calculated by multiplying the amount listed in (1) by the ratio listed in (2); the same applies in (b)):

（１）the individual computed income for that covered fiscal year;

（２）the ratio obtained by deducting the stateless constituent entity effective tax rate for that covered fiscal year from the base tax rate;

ロthe recalculated international minimum tax amount for that covered fiscal year (meaning the sum of the amounts specified by Cabinet Order as the amounts by which the current international minimum tax amount for a past covered fiscal year fell short; the same applies in (a) of the following item and (a) of item (vi));

ハthe international minimum tax amount on undistributed income for that covered fiscal year (meaning the amount specified by Cabinet Order as the international minimum tax amount corresponding to the portion of the individual computed income of that stateless constituent entity (limited to an investment entity, etc.) that was not distributed to other constituent entities; the same applies in (b) of the following item and (b) of item (vi));

ニthe amount of tax on a domestic minimum top-up amount for that covered fiscal year;

五in the case where the stateless constituent entity effective tax rate of a stateless constituent entity belonging to a specified multinational enterprise group, etc. for each covered fiscal year is the base tax rate or more, and there is individual computed income of that stateless constituent entity in that covered fiscal year: the remaining amount after deducting the amount listed in (c) from the sum of the amounts listed in (a) and (b) for that stateless constituent entity:

イthe recalculated international minimum tax amount for that covered fiscal year;

ロthe international minimum tax amount on undistributed income for that covered fiscal year;

ハthe amount of tax on a domestic minimum top-up amount for that covered fiscal year;

六in the case where there is no individual computed income of a stateless constituent entity belonging to a specified multinational enterprise group, etc. in each covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) and (b) for that stateless constituent entity (if, where the adjusted covered taxes for that covered fiscal year are less than zero, the amount by which they fall below zero exceeds the specified adjusted covered taxes prescribed in (c) for that covered fiscal year, the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c)):

イthe recalculated international minimum tax amount for that covered fiscal year;

ロthe international minimum tax amount on undistributed income for that covered fiscal year;

ハthe remaining amount after deducting, from the amount by which the adjusted covered taxes for that covered fiscal year fall below zero where they are less than zero, the specified adjusted covered taxes for that covered fiscal year (meaning the amount calculated by multiplying the individual computed loss for that covered fiscal year of that stateless constituent entity by the base tax rate);

ニthe amount of tax on a domestic minimum top-up amount for that covered fiscal year.

一a minority-owned constituent entity (excluding those listed in the following item and item (iii));

二a minority-owned parent constituent entity (excluding one listed in the following item) or a minority-owned subsidiary constituent entity (excluding one listed in that item);

三an investment entity, etc.

一in the case where the jurisdictional effective tax rate prescribed in (a), (3) in the country of location of a jointly controlled entity, etc. (excluding a stateless jointly controlled entity; hereinafter the same applies up to item (iii)) pertaining to a specified multinational enterprise group, etc. for each covered fiscal year is less than the base tax rate, and there is an amount of jurisdictional group net income prescribed in (a), (1) pertaining to that country of location in that covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c):

イthe current jurisdictional international minimum tax amount pertaining to that country of location for that covered fiscal year (meaning the amount calculated by multiplying the remaining amount after deducting the amount listed in (2) from the amount listed in (1) by the ratio listed in (3); the same applies in (b)):

（１）the amount of jurisdictional group net income (meaning the remaining amount after deducting the amount listed in (ii) from the amount listed in (i); hereinafter the same applies up to item (iii)):

（ｉ）the sum of the individual computed income for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

（ｉｉ）the sum of the individual computed loss for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

（２）the sum of the following amounts:

（ｉ）the amount equivalent to 5 percent of the amount specified by Cabinet Order as the amount of salaries, wages, remuneration, annual allowances, bonuses or other payments of a similar nature, or other expenses, for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

（ｉｉ）the amount equivalent to 5 percent of the amount specified by Cabinet Order as the amount of tangible fixed assets or other assets for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

（３）the ratio obtained by deducting, from the base tax rate, the jurisdictional effective tax rate in that country of location for that covered fiscal year (meaning the ratio that the amount listed in (i) (in the case where the amount listed in (i) for that covered fiscal year exceeds zero and there is an amount of jurisdictional group net income pertaining to that country of location in that covered fiscal year, if there is a past covered fiscal year for which the amount listed in (i) pertaining to that country of location is less than zero, the remaining amount after deducting the amount specified by Cabinet Order as the portion carried forward to that covered fiscal year out of the amount of the portion by which the amount listed in (i) for that past covered fiscal year falls below zero, and in the case where the amount listed in (i) for that covered fiscal year is less than zero, zero) accounts for in the amount listed in (ii); the same applies in the following item):

（ｉ）the jurisdictional adjusted covered tax amount (meaning the sum of the adjusted covered taxes for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location; the same applies in item (iii));

（ｉｉ）the amount of jurisdictional group net income;

ロthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year (meaning the sum of the amounts specified by Cabinet Order as the amounts by which the current jurisdictional international minimum tax amount pertaining to the country of location of a jointly controlled entity, etc. for a past covered fiscal year fell short; the same applies in (a) of the following item and (a) of item (iii));

ハthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year (meaning the amount specified by Cabinet Order as the international minimum tax amount corresponding to the portion of the individual computed income pertaining to that jointly controlled entity, etc. (limited to an investment entity, etc.; the same applies in (c)) that was not distributed to other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc.; the same applies in (b) of the following item and (b) of item (iii));

ニthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

二in the case where the jurisdictional effective tax rate in the country of location of a jointly controlled entity, etc. pertaining to a specified multinational enterprise group, etc. for each covered fiscal year is the base tax rate or more, and there is an amount of jurisdictional group net income pertaining to that country of location in that covered fiscal year: the remaining amount after deducting the amount listed in (c) from the sum of the amounts listed in (a) and (b):

イthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year;

ロthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year;

ハthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

三in the case where there is no amount of jurisdictional group net income pertaining to the country of location of a jointly controlled entity, etc. pertaining to a specified multinational enterprise group, etc. in each covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) and (b) (if, where the jurisdictional adjusted covered tax amount for that covered fiscal year is less than zero, the amount by which it falls below zero exceeds the specified jurisdictional adjusted covered tax amount prescribed in (c) for that covered fiscal year, the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c)):

イthe recalculated country-by-country international minimum tax amount pertaining to that country of location for that covered fiscal year;

ロthe international minimum tax amount on undistributed income pertaining to that country of location for that covered fiscal year;

ハthe remaining amount after deducting, from the amount by which the jurisdictional adjusted covered tax amount for that covered fiscal year falls below zero where it is less than zero, the specified jurisdictional adjusted covered tax amount pertaining to that country of location for that covered fiscal year (meaning the amount calculated by multiplying the remaining amount after deducting the amount listed in (2) from the amount listed in (1) by the base tax rate):

（１）the sum of the individual computed loss for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

（２）the sum of the individual computed income for that covered fiscal year of that jointly controlled entity, etc. and other jointly controlled entities, etc. pertaining to that jointly controlled entity, etc. whose country of location is that country of location;

ニthe amount of tax on a domestic minimum top-up amount pertaining to that country of location for that covered fiscal year;

四in the case where the stateless jointly controlled entity effective tax rate of a stateless jointly controlled entity pertaining to a specified multinational enterprise group, etc. for each covered fiscal year (meaning the ratio that the adjusted covered taxes for that covered fiscal year (in the case where the adjusted covered taxes for that covered fiscal year exceed zero and there is individual computed income of that stateless jointly controlled entity in that covered fiscal year, if there is a past covered fiscal year for which the adjusted covered taxes are less than zero, the remaining amount after deducting the amount specified by Cabinet Order as the portion carried forward to that covered fiscal year out of the amount of the portion by which the adjusted covered taxes for that past covered fiscal year fall below zero, and in the case where the adjusted covered taxes for that covered fiscal year are less than zero, zero) account for in the individual computed income for that covered fiscal year; the same applies in (a), (2) and the following item) is less than the base tax rate, and there is individual computed income of that stateless jointly controlled entity in that covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c) for that stateless jointly controlled entity:

イthe current international minimum tax amount for that covered fiscal year (meaning the amount calculated by multiplying the amount listed in (1) by the ratio listed in (2); the same applies in (b)):

（１）the individual computed income for that covered fiscal year;

（２）the ratio obtained by deducting the stateless jointly controlled entity effective tax rate for that covered fiscal year from the base tax rate;

ロthe recalculated international minimum tax amount for that covered fiscal year (meaning the sum of the amounts specified by Cabinet Order as the amounts by which the current international minimum tax amount for a past covered fiscal year fell short; the same applies in (a) of the following item and (a) of item (vi));

ハthe international minimum tax amount on undistributed income for that covered fiscal year (meaning the amount specified by Cabinet Order as the international minimum tax amount corresponding to the portion of the individual computed income of that stateless jointly controlled entity (limited to an investment entity, etc.; the same applies in (c)) that was not distributed to other jointly controlled entities, etc. pertaining to that stateless jointly controlled entity; the same applies in (b) of the following item and (b) of item (vi));

ニthe amount of tax on a domestic minimum top-up amount for that covered fiscal year;

五in the case where the stateless jointly controlled entity effective tax rate of a stateless jointly controlled entity pertaining to a specified multinational enterprise group, etc. for each covered fiscal year is the base tax rate or more, and there is individual computed income of that stateless jointly controlled entity in that covered fiscal year: the remaining amount after deducting the amount listed in (c) from the sum of the amounts listed in (a) and (b) for that stateless jointly controlled entity:

イthe recalculated international minimum tax amount for that covered fiscal year;

ロthe international minimum tax amount on undistributed income for that covered fiscal year;

ハthe amount of tax on a domestic minimum top-up amount for that covered fiscal year;

六in the case where there is no individual computed income of a stateless jointly controlled entity pertaining to a specified multinational enterprise group, etc. in each covered fiscal year: the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) and (b) for that stateless jointly controlled entity (if, where the adjusted covered taxes for that covered fiscal year are less than zero, the amount by which they fall below zero exceeds the specified adjusted covered taxes prescribed in (c) for that covered fiscal year, the remaining amount after deducting the amount listed in (d) from the sum of the amounts listed in (a) through (c)):

イthe recalculated international minimum tax amount for that covered fiscal year;

ロthe international minimum tax amount on undistributed income for that covered fiscal year;

ハthe remaining amount after deducting, from the amount by which the adjusted covered taxes for that covered fiscal year fall below zero where they are less than zero, the specified adjusted covered taxes for that covered fiscal year (meaning the amount calculated by multiplying the individual computed loss for that covered fiscal year of that stateless jointly controlled entity by the base tax rate);

ニthe amount of tax on a domestic minimum top-up amount for that covered fiscal year.

一a minority-owned jointly controlled entity (excluding those listed in the following item and item (iii));

二a minority-owned parent jointly controlled entity (excluding one listed in the following item) or a minority-owned subsidiary jointly controlled entity (excluding one listed in that item);

三an investment entity, etc.

一the laws and regulations concerning that tax on a domestic minimum top-up amount are laws and regulations specified by Cabinet Order as those containing provisions found to be similar to the provisions concerning the calculation of the net income or loss for the fiscal year (meaning the net income or loss for the fiscal year prescribed in Article 82, item (xxvi); the same applies in item (ii) of the following paragraph) in corporation tax on the international minimum tax amount for each covered fiscal year;

二the laws and regulations concerning that tax on a domestic minimum top-up amount satisfy the requirement of not imposing tax on a domestic minimum top-up amount only in the case where the ultimate parent company, etc. or a partially-owned parent entity holds all of the interests in all constituent entities whose country of location is that country, etc. during the period from the first day of that covered fiscal year to the last day thereof, or any other requirement specified by Cabinet Order.

一under the laws and regulations concerning taxes of that country or region (limited to those enacted before January 1, 2029; the same applies in the following item and item (iii)), taxes on the income of companies, etc. are to be imposed at a tax rate of 20 percent or more;

二under the laws and regulations concerning taxes of that country or region, tax on a domestic minimum top-up amount is to be imposed, or, in the case where the amount of taxes on the income of a company, etc. is found to be too small in light of the net income or loss for the fiscal year of that company, etc., taxes (excluding tax on a domestic minimum top-up amount) are to be imposed, in order to seek an appropriate tax burden, at a tax rate of 15 percent or more on the amount calculated on the basis of the net income or loss for the fiscal year for each covered fiscal year of that company, etc.;

三the laws and regulations concerning taxes of that country or region contain provisions under which, in the case where a company, etc. whose interests are directly or indirectly held by another company, etc. (referred to as a "subsidiary, etc." in this item) does not itself carry out the management, control and operation of its business in the country or region in which its head office or principal office is located, or in any other case, the amount of income of that subsidiary, etc. is deemed to be the amount of proceeds of that other company, etc. and is included in the amount of gross profit, and which, in principle, calculate the amount to be included in the amount of gross profit on the basis of the entire amount of income of that subsidiary, etc.;

四the laws and regulations concerning taxes of that country or region contain provisions that allow the amount of taxes imposed on the income of a company, etc. under the laws and regulations concerning taxes of a country or region other than that country or region to be deducted from the amount of taxes on the income of that company, etc. (limited to those that allow the amount of tax on a domestic minimum top-up amount to be deducted).

一the ratio of the amount listed in (a) to the amount listed in (b) (limited to an amount exceeding zero) is 15 percent or more:

イthe amount specified by Cabinet Order as the sum of the adjusted covered taxes for the covered fiscal year of all constituent entities whose country of location is that country of location (excluding constituent entities excluded from consolidation) and the amount pertaining to the matters specified by Ministry of Finance Order, out of the matters concerning the amount of tax in that country of location for the covered fiscal year of the specified multinational enterprise group, etc. that have been provided for the exchange of information on international taxation pursuant to the laws and regulations of Japan concerning taxation or anything equivalent thereto (limited to the portion pertaining to those constituent entities excluded from consolidation);

ロthe amount specified by Cabinet Order as the amount obtained by adding, to the amount obtained by subtracting the sum of the individual computed loss for the covered fiscal year from the sum of the individual computed income for the covered fiscal year of all constituent entities whose country of location is that country of location (excluding constituent entities excluded from consolidation), the revenue in that country of location for the covered fiscal year of the specified multinational enterprise group, etc. that has been provided for the exchange of information on international taxation pursuant to the laws and regulations of Japan concerning taxation or anything equivalent thereto (limited to the portion pertaining to those constituent entities excluded from consolidation);

二the amount listed in (b) of the preceding item does not exceed the amount listed in paragraph (2), item (i)(a)(2) pertaining to the constituent entity for the covered fiscal year.