①In the case where, in the business year ending on the base date of another group tax sharing corporation that has a group tax sharing full controlling interest with a group tax sharing corporation as of the day on which the income business year of the group tax sharing corporation (meaning a business year in which income before group tax sharing (meaning the amount of income calculated without applying the provisions of Article 57, paragraph (1) (Carryover of Losses), Article 59, paragraphs (3) and (4) (Inclusion in Deductible Expenses of the Net Operating Loss Where Corporate Reorganization Caused a Release from Obligation), Article 62-5, paragraph (5) (Transfer of Assets by Distribution in Kind), this Article and Article 64-7, paragraph (6) (Aggregation of Losses); the same applies hereinafter in this Article) arises (limited to one ending on the day of the end of the business year of the group tax sharing parent corporation pertaining to the group tax sharing corporation); the same applies hereinafter in this Article) ends (hereinafter referred to as the "base date" in this paragraph and the following paragraph), a deficit before group tax sharing (meaning the net operating loss calculated without applying the provisions of Article 59, paragraphs (3) and (4), Article 62-5, paragraph (5), this Article and Article 64-7, paragraph (6); the same applies hereinafter in this Article) arises, the deficit subject to aggregation for the income business year of the group tax sharing corporation is included in deductible expenses, when calculating the amount of income for the income business year.

②The deficit subject to aggregation prescribed in the preceding paragraph means the amount calculated by multiplying the amount listed in item (i) by the ratio of the amount listed in item (ii) to the amount listed in item (iii):

③In the case where, in the business year ending on the base date of another group tax sharing corporation that has a group tax sharing full controlling interest with a group tax sharing corporation as of the day on which the business year showing a loss of the group tax sharing corporation (meaning a business year in which a deficit before group tax sharing arises (limited to one ending on the day of the end of the business year of the group tax sharing parent corporation pertaining to the group tax sharing corporation); the same applies hereinafter in this Article) ends (hereinafter referred to as the "base date" in this paragraph and the following paragraph), income before group tax sharing arises, the income subject to aggregation for the business year showing a loss of the group tax sharing corporation is included in gross profits, when calculating the amount of income for the business year showing a loss.

④The income subject to aggregation prescribed in the preceding paragraph means the amount calculated by multiplying the amount listed in item (i) by the ratio of the amount listed in item (ii) to the amount listed in item (iii):

⑤In applying the provisions of paragraph (1) or paragraph (3), when the income before group tax sharing or the deficit before group tax sharing for the income business year of the group tax sharing corporation referred to in paragraph (1) or the business year ending on the base date prescribed in that paragraph of another group tax sharing corporation prescribed in that paragraph, or for the business year showing a loss of the group tax sharing corporation referred to in paragraph (3) or the business year ending on the base date prescribed in that paragraph of another group tax sharing corporation prescribed in that paragraph (hereinafter referred to as a "group tax sharing business year" up to paragraph (7)), differs from the amount entered as the income before group tax sharing or the deficit before group tax sharing in the documents attached to the return under Article 74, paragraph (1) (Final Returns) for the group tax sharing business year (hereinafter referred to as the "initially reported income before group tax sharing" or the "initially reported deficit before group tax sharing", respectively, in this paragraph), the initially reported income before group tax sharing is deemed to be the income before group tax sharing, and the initially reported deficit before group tax sharing is deemed to be the deficit before group tax sharing, respectively.

⑥In the case where an amended return is filed or a reassessment is made with regard to any of the group tax sharing business years (limited to a business year for which a return under Article 74, paragraph (1) has been filed; the same applies hereinafter in this paragraph and the following paragraph), when all of the following requirements are met, the provisions of the preceding paragraph do not apply to the income business year of the group tax sharing corporation referred to in paragraph (1) or the business year showing a loss of the group tax sharing corporation referred to in paragraph (3):

⑦With regard to the application of the provisions of the preceding two paragraphs after an amended return has been filed or a reassessment has been made for a group tax sharing business year by applying the provisions of the preceding paragraph, the amount entered as an amount listed in each of the following items in the amended return or in the written notice of reassessment prescribed in Article 28, paragraph (2) (Procedures for Reassessment or Determination) of the Act on General Rules for National Taxes pertaining to the reassessment, or in the documents attached to those documents, is deemed to be the amount entered as the amount listed in that item in the return under Article 74, paragraph (1) or in the documents attached to that return:

⑧When the district director finds that, if the provisions of paragraph (5), Article 64-7, paragraphs (4) through (7) or Article 69, paragraph (15) or paragraph (20) (Foreign Tax Credit) or any other provisions specified by Cabinet Order were applied in calculating the amount of income or the net operating loss, or the amount of corporation tax, for each business year of a group tax sharing corporation, the following facts or other facts would arise and this would result in unreasonably reducing the burden of corporation tax on income for the business years of the group tax sharing corporation or other group tax sharing corporations ending on or after the day of the end of each relevant business year, the district director may decide not to apply the provisions of paragraph (5) with regard to each relevant business year and the business years of the other group tax sharing corporations ending on the day of the end of each relevant business year:

⑨Beyond what is provided for in paragraph (5) to the preceding paragraph, necessary matters concerning the application of the provisions of paragraphs (1) through (4) are specified by Cabinet Order.

①In the case where a group tax sharing corporation (limited to a corporation listed in any of the items of Article 64-11, paragraph (1) (Gains or Losses on the Fair Valuation of Assets Accompanying the Commencement of the Group Tax Sharing System) or any of the items of Article 64-12, paragraph (1) (Gains or Losses on the Fair Valuation of Assets Accompanying Participation in the Group Tax Sharing System); hereinafter the same applies in this paragraph) does not fall under the case specified by Cabinet Order as a case where it has had a controlling interest with the group tax sharing parent corporation pertaining to the group tax sharing corporation (in the case where the group tax sharing corporation is the group tax sharing parent corporation, any of the other group tax sharing corporations) continuously from the day five years before the day on which the group tax sharing approval became effective or the date of establishment of the group tax sharing corporation, whichever is later, until the day on which the group tax sharing approval became effective, when the case does not fall under the case specified by Cabinet Order as a case where the group tax sharing corporation and another group tax sharing corporation conduct business jointly after the group tax sharing approval became effective, the amount, out of the deficit before group tax sharing prescribed in paragraph (1) of the preceding Article arising in the business year of the group tax sharing corporation (excluding a business year to which the provisions of Article 64-14, paragraph (1) (Exclusion of Losses on the Transfer of Specified Assets from Deductible Expenses) apply) (in the case where the provisions of paragraph (4) apply, the amount obtained by deducting the amount deemed not to exist under that paragraph), that is up to the net operating loss on the transfer of specified assets arising in the application period of the business year (meaning the period from the day on which the group tax sharing approval became effective until the day on which three years have elapsed from that day or the day on which five years have elapsed from the day on which the group tax sharing corporation last came to have a controlling interest with the group tax sharing parent corporation pertaining to the group tax sharing corporation (in the case where the group tax sharing corporation is the group tax sharing parent corporation, the day on which it last came to have a controlling interest with the one, among the other group tax sharing corporations, whose day of last coming to have a controlling interest with the group tax sharing corporation is the earliest; referred to as the "date the controlling interest arose" in item (i) of the following paragraph), whichever is earlier), is deemed not to exist with regard to the application of the provisions of that Article.

②The net operating loss on the transfer of specified assets prescribed in the preceding paragraph means the amount obtained by deducting the amount listed in item (ii) from the amount listed in item (i):

③With regard to the application of the provisions of paragraph (1) in a business year of the group tax sharing corporation referred to in that paragraph that is specified by Cabinet Order as a business year in which a large amount of depreciation allowances arises, the phrase "the amount, out of the deficit before group tax sharing prescribed in paragraph (1) of the preceding Article arising in the business year of the group tax sharing corporation (excluding a business year to which the provisions of Article 64-14, paragraph (1) (Exclusion of Losses on the Transfer of Specified Assets from Deductible Expenses) apply) (in the case where the provisions of paragraph (4) apply, the amount obtained by deducting the amount deemed not to exist under that paragraph), that is up to the net operating loss on the transfer of specified assets arising in the application period of the business year" in that paragraph is deemed to be replaced with "the deficit before group tax sharing prescribed in paragraph (1) of the preceding Article arising in the business year specified by Cabinet Order prescribed in paragraph (3) that contains a day within the application period of the group tax sharing corporation".

④In the case where there is an amount to be included in deductible expenses under Article 64-8 (Inclusion in Deductible Expenses of Losses in the Case of a Merger, etc. of a Group Tax Sharing Corporation) in each business year of a group tax sharing corporation, when there is an amount that would be deemed not to exist if the provisions of this Article were applied to the business year in which the net operating loss of the other domestic corporation referred to in that Article to which the provisions of that Article apply arose (in the case where the other domestic corporation is a domestic corporation whose residual assets have been determined and the other domestic corporation has two or more shareholders, etc., the amount calculated by dividing the amount equivalent to the amount deemed not to exist by the total number or the total amount of the other domestic corporation's issued shares or capital contributions (excluding the shares that the other domestic corporation holds in itself and the capital contributions made thereby) and then multiplying the result by the number or the amount of the shares of or capital contributions to the other domestic corporation held by the group tax sharing corporation; hereinafter referred to as the "amount subject to restriction" in this paragraph), the amount, out of the deficit before group tax sharing prescribed in paragraph (1) of the preceding Article arising in each relevant business year of the group tax sharing corporation, that is up to the amount subject to restriction is deemed not to exist with regard to the application of the provisions of that Article.

⑤The amount that may be deducted from the net operating loss on the transfer of specified assets prescribed in paragraph (1) and other necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.