①The term "international minimum tax residual amount" as used in this Section means the amount calculated by multiplying the domestic group international minimum tax residual amount prescribed in Article 82-11, paragraph (2) (International Minimum Tax Residual Amount) of a specified multinational enterprise group, etc. (meaning a specified multinational enterprise group, etc. prescribed in Article 82, item (iv) (Definitions); hereinafter the same applies in this paragraph) for each covered fiscal year of a foreign corporation that is a constituent entity (meaning a constituent entity prescribed in Article 82, item (xiii); hereinafter the same applies in this paragraph) having a permanent establishment, etc. (meaning a permanent establishment, etc. prescribed in item (vi) of that Article, limited to one whose country of location (meaning the country of location prescribed in item (vii) of that Article; hereinafter the same applies in this Article) is Japan; hereinafter the same applies in this paragraph) belonging to the specified multinational enterprise group, etc., by the ratio obtained by adding together the ratio calculated by multiplying by 50 percent the ratio calculated, as specified by Cabinet Order, as the proportion of the number of employees, etc. prescribed in Article 82-11, paragraph (1) of the permanent establishment, etc. of the foreign corporation to the total number of employees, etc. prescribed in that paragraph of the constituent entities belonging to the specified multinational enterprise group, etc. (limited to those whose country of location is Japan; hereinafter the same applies in this paragraph), and the ratio calculated by multiplying by 50 percent the ratio calculated, as specified by Cabinet Order, as the proportion of the amount of tangible assets of the permanent establishment, etc. of the foreign corporation to the total amount of tangible assets of the constituent entities.

②The calculation of the international minimum tax residual amount in the case where there is a flow-through entity prescribed in Article 82, item (v) whose country of location is Japan, and other necessary matters concerning the calculation set forth in the preceding paragraph are specified by Cabinet Order.

①The tax base of corporation tax on the international minimum tax residual amount for each covered fiscal year imposed on a foreign corporation is the tax base international minimum tax residual amount pertaining to a foreign corporation for each covered fiscal year.

②The tax base international minimum tax residual amount pertaining to a foreign corporation for each covered fiscal year is the international minimum tax residual amount for each covered fiscal year.

The amount of corporation tax on the international minimum tax residual amount for each covered fiscal year imposed on a foreign corporation is the amount calculated by multiplying the tax base international minimum tax residual amount pertaining to a foreign corporation for each covered fiscal year by a tax rate of 90.7 percent.

The provisions of Part II, Chapter II, Section 3, Subsection 4 (Filing of Returns, Payment, etc.) (excluding Article 82-15 (Filing of Returns via Electronic Data Processing System) and Article 82-16 (Special Provisions for Cases Where Filing of Returns via Electronic Data Processing System Is Difficult)) apply mutatis mutandis to the filing of returns, payment and requests for Reassessment under Article 23, paragraph (1) of the Act on General Rules for National Taxes (Request for Reassessment) with regard to corporation tax on the international minimum tax residual amount for each covered fiscal year of a foreign corporation. In this case, the phrase "tax base international minimum tax residual amount pertaining to a domestic corporation" in Article 82-14, paragraph (1), item (i) (Final Returns Pertaining to the International Minimum Tax Residual Amount) is deemed to be replaced with "tax base international minimum tax residual amount pertaining to a foreign corporation"; the phrase "tax base international minimum tax residual amount pertaining to a domestic corporation" in item (ii) of that paragraph is deemed to be replaced with "tax base international minimum tax residual amount pertaining to a foreign corporation"; and the phrase "the preceding Article" is deemed to be replaced with "Article 145-4 (Calculation of Tax Amount)".

①The term "domestic minimum tax amount" as used in this Section means the amount specified in each of the following items in accordance with the category of foreign corporation listed in that item:

②The domestic minimum tax amount pertaining to the permanent establishment, etc. of a constituent entity prescribed in item (i) of the preceding paragraph means the amount calculated with regard to the permanent establishment, etc. of the foreign corporation listed in that item in accordance with the provisions of Article 82-19, paragraphs (2) through (4), paragraphs (8) through (14), paragraph (16) and paragraph (17) (Domestic Minimum Tax Amount).

③The domestic minimum tax amount pertaining to the permanent establishment, etc. of a jointly controlled entity, etc. prescribed in paragraph (1), item (ii) means the amount calculated with regard to the permanent establishment, etc. of the foreign corporation listed in that item in accordance with the provisions of Article 82-19, paragraphs (5) through (7), the provisions of paragraph (8) and paragraphs (11) through (14) of that Article as applied mutatis mutandis pursuant to paragraph (15) of that Article, and the provisions of paragraph (16) and paragraph (17) of that Article.

④The calculation of the domestic minimum tax amount and other necessary matters concerning the application of the provisions of the preceding two paragraphs are specified by Cabinet Order.

①The tax base of corporation tax on the domestic minimum tax amount for each covered fiscal year imposed on a foreign corporation is the tax base domestic minimum tax amount pertaining to a foreign corporation for each covered fiscal year.

②The tax base domestic minimum tax amount pertaining to a foreign corporation for each covered fiscal year is the domestic minimum tax amount for each covered fiscal year.

The amount of corporation tax on the domestic minimum tax amount for each covered fiscal year imposed on a foreign corporation is the amount calculated by multiplying the tax base domestic minimum tax amount pertaining to a foreign corporation for each covered fiscal year by a tax rate of 75.3 percent.

The provisions of Part II, Chapter II, Section 4, Subsection 4 (Filing of Returns, Payment, etc.) (excluding Article 82-23 (Filing of Returns via Electronic Data Processing System) and Article 82-24 (Special Provisions for Cases Where Filing of Returns via Electronic Data Processing System Is Difficult)) apply mutatis mutandis to the filing of returns, payment and requests for Reassessment under Article 23, paragraph (1) of the Act on General Rules for National Taxes (Request for Reassessment) with regard to corporation tax on the domestic minimum tax amount for each covered fiscal year of a foreign corporation listed in the items of Article 145-6, paragraph (1) (Domestic Minimum Tax Amount). In this case, the phrase "tax base domestic minimum tax amount pertaining to a domestic corporation" in Article 82-22, paragraph (1), item (i) (Final Returns Pertaining to the Domestic Minimum Tax Amount) is deemed to be replaced with "tax base domestic minimum tax amount pertaining to a foreign corporation"; the phrase "tax base domestic minimum tax amount pertaining to a domestic corporation" in item (ii) of that paragraph is deemed to be replaced with "tax base domestic minimum tax amount pertaining to a foreign corporation"; and the phrase "the preceding Article" is deemed to be replaced with "Article 145-8 (Calculation of Tax Amount)".