The provisions of Articles 130 through 132-2 (Reassessment Related to a Blue Return, etc.) apply mutatis mutandis to a Reassessment or determination pertaining to corporation tax on income for each business year of a foreign corporation, corporation tax on the international minimum tax residual amount for each covered fiscal year of a foreign corporation, corporation tax on the domestic minimum tax amount for each covered fiscal year of a foreign corporation and corporation tax on retirement pension funds of a foreign corporation.

In the case where the district director makes a Reassessment or determination with regard to corporation tax on income pertaining to the domestic source income listed in Article 141, item (i), (a) (Tax Base) (hereinafter referred to as "income attributable to a permanent establishment" in this Article) for each business year of a foreign corporation, when it is found that any acts or calculations of the foreign corporation would, if allowed, result in unreasonably reducing the burden of corporation tax through an increase in the amount to be deducted from the amount of income pertaining to the income attributable to a permanent establishment for each business year, an increase in the amount to be deducted from the amount of corporation tax on income pertaining to the income attributable to a permanent establishment for each business year, a decrease in the amount of profit or an increase in the amount of loss pertaining to internal transactions prescribed in Article 138, paragraph (1), item (i) (Domestic Source Income), or any other grounds, the district director may, notwithstanding the acts or calculations, calculate the tax base of corporation tax on income pertaining to the income attributable to a permanent establishment, the net operating loss, or the amount of corporation tax on income pertaining to the income attributable to a permanent establishment of the foreign corporation for each business year, based on their own recognition.

①In the case where a Reassessment (including a decision or ruling on an appeal, or a judgment on an action, pertaining to a disposition on a request for Reassessment (meaning a request for Reassessment under the provisions of Article 23, paragraph (1) (Request for Reassessment) of the Act on General Rules for National Taxes; the same applies in the following Article) with regard to the corporation tax; hereinafter referred to as a "Reassessment or similar decision" in this paragraph) has been made with regard to the corporation tax pertaining to an interim return (limited to one containing the matters listed in the items of Article 144-4, paragraph (1) or the items of paragraph (2) of that Article (Matters to be Entered in Interim Return in the Case of Provisional Settlement of Accounts)) or a Final Return filed by a foreign corporation, when, as a result of the Reassessment or similar decision, the amount listed in Article 144-4, paragraph (5), item (i) or item (ii) or paragraph (6), item (i), or the amount listed in Article 144-6, paragraph (1), item (v) (Final Returns) (in the case falling under the provisions of item (viii) of that paragraph, the amount listed in that item), the amount listed in item (vi) of that paragraph (in the case falling under the provisions of item (ix) of that paragraph, the amount listed in that item) or the amount listed in paragraph (2), item (iii) of that Article has increased, the district director refunds the amount of tax equivalent to the amount of the increase to the foreign corporation.

②The provisions of Article 133, paragraph (2) (Refund of Income Tax upon a Reassessment or Similar Decision) apply mutatis mutandis in the case of calculating interest on a refund with regard to a refund under the provisions of the preceding paragraph, and the provisions of paragraph (3) of that Article apply mutatis mutandis in the case of the appropriation of a refund under the provisions of the preceding paragraph for the unpaid portion of corporation tax on income pertaining to domestic source income specified in Article 141, item (i) or item (ii) (Tax Base) for the business year pertaining to the interim return set forth in that paragraph or the business year pertaining to the Final Return set forth in that paragraph, which was filed by the foreign corporation set forth in that paragraph.

③Methods for appropriation of a refund (including interest on a refund related thereto) pursuant to the provisions of paragraph (1), and other necessary matters concerning the application of the provisions of that paragraph are specified by Cabinet Order.

①In the case where a determination under the provisions of Article 25 (Determination) of the Act on General Rules for National Taxes has been made with regard to the corporation tax for the business year pertaining to an interim return of an ordinary corporation which is a foreign corporation and has filed the interim return, when there is any amount listed in Article 144-6, paragraph (1), item (xi) or paragraph (2), item (v) (Final Returns) pertaining to the determination, the district director refunds the amount of interim payment equivalent to that amount to the ordinary corporation.

②In the case where a Reassessment (including a decision or ruling on an appeal, or a judgment on an action, pertaining to a disposition, etc. (meaning a disposition on a request for Reassessment or a determination under the provisions of Article 25 of the Act on General Rules for National Taxes) with regard to the corporation tax; hereinafter referred to as a "Reassessment or similar decision" in this paragraph) has been made with regard to the corporation tax for the business year pertaining to an interim return of an ordinary corporation which is a foreign corporation and has filed the interim return, when, as a result of the Reassessment or similar decision, the amount listed in Article 144-6, paragraph (1), item (xi) or paragraph (2), item (v) has increased, the district director refunds the amount of interim payment equivalent to the amount of the increase to the ordinary corporation.

③The provisions of Article 134, paragraph (3) (Refund of Interim Payment Due to a Reassessment or Similar Decision or Determination Related to a Final Return) apply mutatis mutandis in the case where a refund under the provisions of the preceding two paragraphs is made; the provisions of paragraph (4) of that Article apply mutatis mutandis in the case of calculating interest on a refund with regard to a refund under the provisions of the preceding two paragraphs; the provisions of paragraph (5) of that Article apply mutatis mutandis in the case of the appropriation of a refund under the provisions of the preceding two paragraphs for the unpaid portion of corporation tax on income pertaining to domestic source income specified in Article 141, item (i) or item (ii) (Tax Base) for the business year pertaining to the interim payment that was used as the basis of the calculation of the amount of the refund; and the provisions of Article 134, paragraph (6) apply mutatis mutandis to a refund under the provisions of paragraph (3) of that Article as applied mutatis mutandis pursuant to this paragraph. In this case, the phrase "Article 74, paragraph (1)" in paragraph (4), item (i) of that Article is deemed to be replaced with "Article 144-6, paragraph (1) or paragraph (2) (Final Returns)", and the phrase "Article 74, paragraph (1)" in item (ii) of that paragraph with "Article 144-6, paragraph (1) or paragraph (2)".

④Methods for appropriation of a refund (including interest on a refund related thereto) pursuant to the provisions of paragraph (1) or paragraph (2), and other necessary matters concerning the application of the provisions of paragraph (1) or paragraph (2) are specified by Cabinet Order.