Supplementary Provisions, Article 18Transitional Measures Concerning Foreign Tax Credits
第十八条(外国税額の控除に関する経過措置)
With regard to the application of the provisions of Article 69, paragraphs (2) and (3) of the New Corporation Tax Act pertaining to the deduction from the amount of corporation tax for each business year of a domestic corporation starting during the period from April 1, 1989 to March 31, 1994, the term "preceding three years" in those provisions is deemed to be replaced with "preceding five years"; provided, however, that with regard to the application of those provisions in a business year starting during the period from April 1, 1993 to March 31, 1994, there is to be no limitation on a creditable amount under paragraph (2) of that Article and no creditable amount of the foreign country's corporate tax under paragraph (3) of that Article for a business year starting during the period from April 1, 1989 to March 31, 1990.
The provisions of Article 69, paragraph (4) of the New Corporation Tax Act apply to the amount of dividends, etc. prescribed in that paragraph that a domestic corporation receives in each business year starting on or after April 1, 1989, and with regard to the amount of dividends, etc. prescribed in Article 69, paragraph (4) of the Former Corporation Tax Act that a domestic corporation received in each business year that started before that date, the provisions then in force continue to govern.
The provisions of Article 69, paragraph (5) of the New Corporation Tax Act apply to the amount of the foreign country's corporate tax prescribed in paragraph (5) of that Article that has been reduced after the provisions of paragraphs (1) through (3) of that Article were applied, and with regard to the amount of the foreign country's corporate tax prescribed in paragraph (5) of that Article that has been reduced after the provisions of Article 69, paragraphs (1) through (3) of the Former Corporation Tax Act were applied, the provisions then in force continue to govern.
新法人税法第六十九条第五項の規定は、同条第一項から第三項までの規定の適用を受けた後に減額された同条第五項に規定する外国法人税の額について適用し、旧法人税法第六十九条第一項から第三項までの規定の適用を受けた後に減額された同条第五項に規定する外国法人税の額については、なお従前の例による。